Bombay HC says Surplus Does Not Defeat Philanthropic Exemption

The Bombay High Court held that a hospital’s philanthropic character must be assessed by examining its objects, actual activities and application of funds—not merely its annual surplus or the proportion spent on indigent patients. Finding no established diversion of funds for private benefit, the Court directed approval under Section 10(23C)(via) for AYs 2002–03 to 2010–11 and AYs 2011–12 to 2021–22.