DCIT(EXEMPTIONS)-1(1), MUMBAI, MUMBAI vs. ADITYA BIRLA FOUNDATION, MUMBAI

ITA 7607/MUM/2025Status: DisposedITAT Mumbai28 April 2026AY 2015-1628 pages
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What were the facts?

The assessee, Aditya Birla Foundation, a charitable trust, leased its hospital building to Aditya Birla Health Services Ltd. The Revenue challenged the exemption claimed under Section 11, alleging violations of Section 13(1)(c) and related provisions. Another issue concerned the taxability of accrued but unreceived interest income.

What did the Tribunal hold?

The Tribunal held that the issues were covered by previous decisions in the assessee's own case. While the provision for indigent patients was not allowed as an application of income, actual reimbursements made to such patients were allowed.

What were the issues?

Whether leasing a hospital to a related entity violates Section 13(1)(c) and impacts exemption under Section 11, and whether accrued but unreceived interest is taxable.

Which sections of the Income-tax Act were involved?

Section 11,Section 13(1)(c),Section 13(2)(a),Section 13(2)(b),Section 13(3),Section 11(1A),Section 11(2),Section 12A,Section 234B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH MUMBAI

Before: HONBLE JUSTICE (RETD.) C V BHADANG & SHRI GIRISH AGRAWAL

Hearing: 25.03.2026Pronounced: 28.04.2026

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These captioned appeals filed by the Revenue and assessee are against the orders of CIT(A) / National Faceless Appeal Centre (NFAC), Delhi, vide order nos.- i. ITBA/NFAC/S/250/2025-26/1078104301(1), dated, 02.07.2025, passed against the assessment order by Income-

2 ITA Nos. 6000/Mum/2025 and Ors. Aditya Birla Foundation AYs 2013-14 to 2015-16 tax Officer (E)-1(1). Mumba

The order continues below.

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