Christian Medical College Ludhiana Society Vs CIT (Exemptions) (ITAT Chandigarh)
The Income Tax Appellate Tribunal (ITAT), Chandigarh, allowed two appeals filed by the assessee-society concerning its registration under Section 12AB and approval under Section 80G(5) of the Income Tax Act.
The first appeal challenged the order granting registration under Section 12AB(1)(b) for Assessment Years 2027-28 to 2031-32 by classifying the assessee as a religious entity instead of a religious-cum-charitable entity. The second appeal challenged the order denying approval under Section 80G(5) on the ground that the assessee was engaged in religious activities.
The assessee submitted that none of its actual activities could be categorized as religious. It relied upon its financial statements, supporting documents, and the Tribunal’s earlier decision in its own case granting approval under Section 80G(5), which had subsequently been affirmed by the Punjab & Haryana High Court.
The Tribunal noted that the assessee-society was established in 1894 and had developed into a medical institution engaged in healthcare, education, and research. It operated medical colleges, collaborated with Government bodies and institutions, provided free or subsidized treatment to vulnerable and underserved groups, and offered undergraduate, postgraduate, and super-specialty education. According to the Tribunal, the services were rendered without discrimination, and patients and students belonged to different religions and social backgrounds. Financial concessions were extended based on economic considerations.
