While admitting an appeal by the Revenue against the ITAT Delhi’s order granting relief to Patanjali, the Delhi High Court recently ruled that propagation of yoga, Vedic philosophy, practice of yoga, education with respect to yoga are to be considered as ‘medical relief’for the purpose of granting exemption under the provisions of the Income Tax Act, 1961.
The revenues contention was that the activities of the assesse registered as charitable trust to the extent that its activities extend to providing services of general public utility. The revenue also added that it provides medical aid through learning from various camps and other modes.
During the proceedings both AO and CIT were in opinion that yoga education is disseminated by campus, specific schools or courses, etc. would address only a section of the population, which may be of benefit for specific ailments. The Revenue had also relied upon subsequent amendment to Section 2(15) of the Act that “charitable purpose” includes relief of the poor, education, medical relief, preservation of environment.
The Tribunal concluded upon analysis of the practice of yoga that it confers positive relief to certain ailments such as asthma, migraine, hypertension, stress, etc. and promotes wellness and well-being generally. So the court is of the opinion that no substantial question of law arises on this aspect.
The bench comprising of Justice S.Ravindra Bhat and Justice Sanjiv Sachdeva has observed that “the mere inclusion of yoga specifically w.e.f. 01.04.2016 did not per se imply that it came to be included as a specific charitable category on the same lines as education, medical relief, relief to the poor, etc but that dissemination of yoga or vedic philosophy or the practice of yoga or education with respect to yoga was well within the larger term “medical relief”.”
Read the full text of the Order below.
