Allowing the petition the Court held that the hospital was not a trust or institution registered under S.12AA. The hospital did not fall within the ambit of any of the sub-clauses of S. 10(23C) specified in S. 11(3)(d). There was a general allegation of breach of S. 11 to 13, without stating why such violation was alleged. Violation of S. 11(2) had been alleged only as a consequence of violation of the provisions of S. 11(3)(d) of the Act. Accordingly on the reasons recorded, the Assessing Officer could not have formed the belief that income chargeable to tax had escaped assessment. The notice of reassessment was not valid. (AY. 2016 -17)