Section 80G Recognition Denied as Trust Operated Hospital on Revenue-Sharing Model

Jeevan Rekha Trust Vs CIT (Exemption) (ITAT Ranchi) CORE ISSUE : Whether a trust earning income by outsourcing its hospital building to a private entity and receiving consideration as a percentage of hospital turnover, with substantial recurring surplus and minimal charitable outgo, is entitled to recognition under Section 80G of the Income-tax Act, 1961. BACKGROUND :- The assessee trust had acquired a building for the purpose of running a hospital. However, being unable to operate the hospital on its own, the trust outsourced the hospital operations to Blue Sapphire Healthcare Private Limite...