TaxTMI 
TaxTMI 
2026 (2) TMI 1142
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....the Income Tax Appellate Tribunal, Division Bench "B" Chandigarh (for short - the Tribunal). RELEVANT FACTS 2. The respondent is a society registered under the Societies Registration Act, 1957 which started to operate in the year 2014. The aims and objects of the respondent society as per its Memorandum of Association, are as follows:- "i. To help in the treatment of patients with liver disease. ii. To promote, educate and spread knowledge of Liver disease. iii. To conduct surveys on liver problems. iv. To hold conferences, symposia, seminars, workshops, etc. to disseminate knowledge on the subject of liver disease. v. To help in the treatment of poor patients suffering from liver diseases.....
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....countant was then heard by the CIT(E). After considering the submissions made on behalf of the respondent-society and the supporting evidence filed before her, the CIT(E) found that the total receipts of the respondent-society for the financial year 2014-2015 were Rs. 35,05,000/- out of which Rs. 22,79,078/- were spent for holding of conferences resulting in a net surplus of Rs. 10,06,284/-. The receipts of the respondent-society were further found to be primarily through donations made by pharmaceutical companies with a meager amount received on account of registration fee paid by the attendees of the conferences organized by the respondent-society. 4. For the financial year 2015-2016 the CIT(E) found that the donations received by the ....
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....are Outcomes Institute of New Mexico Health Science Centre (for short - ECHO Institute) which was a project undertaken by Post Graduate Institute of Medical Education & Research, Chandigarh (for short - PGIMER). Under such programme medical officers posted in the prisons of Punjab were being educated so that they could treat prisoners diagnosed with hepatitis C and other liver diseases. It was further submitted that the respondent-society had also done screening of prisoners in Punjab and was regularly holding video conferences with medical officers posted in the prisons in Punjab. It was still further submitted that test kits for diagnosing liver diseases had also been distributed by the respondent-society, free of cost, in all prisons in ....
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....ty, then and now, are the same, the present appeal be dismissed. DISCUSSION AND CONCLUSION 9. The respondent-society, registered under the Societies Registration Act, 1957, is operating since the year 2014. On 12.02.2016, the respondent-society filed an application before the CIT(E) seeking therein registration under Section 12A of the Act on the ground that all its activities were charitable. After considering the submissions made and evidence produced on behalf of the respondent-society, the CIT(E) noted that for the financial year 2014-2015 the total receipts of the respondent-society were to the tune of Rs. 35,05,000/- and a major bulk of such receipts was through donations received by it from pharmaceutical companies with only a ....
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.... on behalf of the respondent-society which were to the effect that not only was the respondent-society holding conferences which led to enhancement of knowledge of medical professionals which in turn benefitted the society at large but the respondent-society was also implementing the ECHO project in collaboration with the University of New Mexico Health Science Centre and under the guidance of the PGIMER, Chandigarh; under the said ECHO project the respondent-society was helping the prisoners in Punjab who were suffering from liver diseases and that the respondent-society was also distributing, free of cost, test kits to diagnose if any of the prisoners in Punjab was suffering from liver diseases. 11. It was fairly admitted before us tha....