Sibia Healthcare Pvt. Ltd. Vs DCIT (ITAT Chandigarh)
Software-Generated Patient Data Found Unreliable- Faulty Hospital Software Can’t Inflate Revenue – ₹391 Lakh Addition in Sibia Healthcare Remanded for De Novo Assessment
Assessee, a healthcare institution, was subjected to survey action u/s 133A during which certain documents were impounded. These documents contained monthly sheets giving total number of OPD & IPD patients treated at the hospital. As per these sheets, 50,538 OPD patients & 11,358 IPD patients were shown to have been treated, whereas the regular books reflected only 13,147 OPD patients & 3,420 IPD patients. AO found discrepancy in the number shown in these sheets as generated by the software being used by Assessee & the figures as reported in the regular books of accounts. The books of Assessee were rejected u/s 145(3) & the actual receipts were determined on the basis of impounded documents, leading to an addition of ₹391.47 lakh in the hands of Assessee.
Assessee contended that the impounded list was only an estimated list prepared for empanelment with various Govt departments & that the software-generated reports were not correct when run for multiple months. It was explained that out of 50,538 visits in the OPD, chargeable visits were only 12,642, while empanelled patients, IPD revisits & OPD revisions had been separately highlighted. Assessee further contended that the software had technical issues in generating reports of more than one month & therefore the reports captured incorrect information. A complete analysis of the software was submitted in digital form to support these explanations.
