ASHOK GONDHIA MEMORIAL TRUST,RAJKOT vs. THE ITO EXEMPTION, WARD -1, RAJKOT, RAJKOT

ITA 112/RJT/2026Status: DisposedITAT Rajkot10 April 2026AY 2015-168 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the issue is squarely covered by its own previous decisions in favor of the assessee. The compensation received should be treated as income for charitable purposes and the benefit of Section 11 should be allowed.

What were the facts?

The assessee, Ashok Gondhia Memorial Trust, received compensation of Rs. 2,30,00,004/- from Wockhardt Hospitals Ltd. The Assessing Officer treated this as business income and denied the benefit of Section 11 of the Income Tax Act. The CIT(A) upheld this decision.

What were the issues?

Whether compensation received from a hospital management agreement constitutes business income or income for charitable purposes, and if the benefit of Section 11 of the Act is admissible to the trust.

Which sections of the Income-tax Act were involved?

Section 11,Section 144,Section 263,Section 2(15)

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

Hearing: 19/02/2026Pronounced: 10/04/2026

Per, Dr. Arjun Lal Saini, AM:

Captioned appeal filed by the assessee, pertaining to Assessment Year 2015-16, is directed against the order passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi / Commissioner of Income-tax (Appeals) (in short ‘Ld. CIT(A)’), dated 03.12.2025, which in turn arises out of an assessment order passed by the Assessing Officer u/s. 144 r.w.s.263 of t

The order continues below.

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