MAJ Hospital v. DCIT (2018) 173 ITD 554 / 196 TTJ 1149 /( 2019) 173 DTR 236(Cochin)(Trib.)

S. 11 : Property held for charitable purposes–Nursing school located in hospital’s premises-Running hospital and nursing school were intricately connected and dependent on each other and thus, was one inseparable activity entitling to exemption. [S.2(15), 12A]

Assessee  was running hospital along with nursing school. AO granted exemption claimed by assessee under S. 11 in respect of income received from hospital, however, denied same with respect to nursing school. CIT(A) also confirmed the denial of exemption .  On appeal by revenue the Tribunal held that since nursing school was located within hospital’s premises and students of nursing school got training in hospital, assessee’s activities of running hospital and nursing school were intricately connected and dependent on each other and thus, was one inseparable activity and therefore, both were entitled to exemption. (AY.2011-12)