2026 (3) TMI 890

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.... grounds are independent and without prejudice to each other - 1. On the facts and in the prevailing circumstances of the case and in Law, the Ld. CIT(A)-NFAC erred in confirming the addition made the Ld. Assessing Officer without appreciating the fact that the Ld. Assessing Officer has completed the assessment by issuing the invalid notices including the show cause notice, thereby making the entire assessment proceedings bad in law. Hence, the addition of Rs. 16,05,432 may please be deleted. 2. On the facts and in the prevailing circumstances of the case and in Law, the Ld. CIT(A)-NFAC erred in confirming the addition made the Ld. Assessing Officer without appreciating the fact that the notice under section 143(2) has bee....

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....t for claiming the exemption u/s. 10(23C)(iiiae) of the Act the assessee is not required to get any registration under the Income-tax Act and that ld. Assessing Officer was satisfied with his submissions as well as the charitable objects carried out by the assessee. However, ld. Assessing Officer has denied the exemption of Rs. 16,05,432/- claimed by the assessee u/s. 10(23C)(iiiae) of the Act solely on the ground that assessee failed to prove the genuineness of the accounts with specific, cogent and reliable evidences and after allowing the benefit of deficit of Rs. 2,12,615/- has made the addition at Rs. 13,92,820/-. Aggrieved assessee preferred appeal before ld.CIT(A) but failed to succeed. Now the assessee is in appeal before this Tribu....

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....medical care for people living with serious illness and is mainly focussed on providing relief from the systems and stress of illness. Such palliative care is provided by specially trained team of Doctors, Nurses and other Specialists and it is mainly provided for the patients who are of any age and any stage in serious illness. The assessee has been claiming the benefit of exemption u/s. 10(23C)(iiiae) of the Act which is applicable for any hospital or other institution for the reception and treatment of persons requiring medical attention or rehabilitation, existing solely for philanthropic purposes and not for the purpose of profits, if the aggregate annual receipts of such hospital or institution do not exceed the amount of annual recei....