No exemption u/s 10(23C) if institution exists apparently for philanthropic purpose and in reality for profits

Brief about the case The Assessee was registered under the Societies’ Registration Act, 1860 with its main objects to relieve persons suffering from disease or illhealth or requiring medical aid by establishing, constructing and maintaining or assisting Charitable Dispensaries, Hospitals, Convalescent Homes, Sanitoria and Maternity Homes etc. The provisions of section 10 (23C) (via) of the Act became applicable to the petitioner with effect from A.Y.2009-10 as its annual receipts exceeded rupees one crore. The assessee, therefore, made an application in accordance with the Income Tax Rules s...