VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawOrders and instructions2021 › Order
Order of the Board 31 May 2021 Read in part

Approval of Raj Retina and Eye Care Centre, Patna as a hospital under the proviso to section 17(2)(viii) for employer-borne eye treatment

An order issued by the Central Board of Direct Taxes, dated 31 May 2021. Issued under sub-clause (b) of clause (ii) of the proviso to clause (viii) of sub-section (2) of section 17, read with rules 3A(1) and 3A(2) of the Income-tax Rules, 1962.

What this is

This is an approval order issued by the Principal Chief Commissioner of Income-tax, Bihar and Jharkhand, Patna, and not by the Board. It approves M/s Raj Retina and Eye Care Centre, Patel Nagar, Patna (PAN AAGCR6300M) as a hospital for the purposes of sub-clause (b) of clause (ii) of the proviso to clause (viii) of sub-section (2) of section 17 of the Income-tax Act, 1961, read with rules 3A(1) and 3A(2) of the Income-tax Rules, 1962. The approval is confined to treatment of the eye.

This is an order of the Board. An order is issued under a power the Act itself gives the Board — most often section 119, which lets it direct its own officers and, in the cases the section names, relax a requirement. Read the enabling words before deciding how far it reaches: the power is administrative, and it cannot rewrite the charge.

What it does

Once the hospital holds this approval, any sum paid by an employer in respect of expenditure actually incurred by an employee on his own medical treatment, or that of a member of his family, at this hospital is not treated as a perquisite in the employee's hands for the purposes of sections 15, 16 and 17. The order restricts the benefit to diseases or ailments related to the eye only, expressly excluding ear, nose and throat, as prescribed at serial number (e) under rule 3A(2). It records that the employer will not be liable to deduct tax at source on such sums. The approval is not transferable, applies only to the premises stated, is open to departmental inspection, and may be withdrawn if it was obtained by misrepresentation or if the rule 3A(1) conditions cease to be satisfied.

Why it was issued

Section 17(2)(viii) read with its proviso keeps employer-borne medical expenditure outside the perquisite charge where the treatment is taken at a hospital approved by the Principal Chief Commissioner for prescribed diseases. That approval is a precondition, granted hospital by hospital, and it has to be applied for and renewed. This order disposes of this hospital's application. It records that the guidelines in rules 3A(1) and 3A(2) were considered, identifies the ailments covered, and fixes the period for which the department will treat the hospital as approved.

Who it reaches

It binds the income-tax department, which must give effect to the approval for the period stated. It does not bind the assessee, and it does not bind a court or the Tribunal. Its practical beneficiaries are employees treated at this hospital and their employers, who may hold the department to it while it stands.

From when

Takes effect from 27.05.2021 and remains in force till 26.05.2024. An application for renewal is to be submitted at least 30 days before expiry of the current approval.

What to watch

The approval is disease-specific: the eye only, with ear, nose and throat expressly excluded. Treatment of anything else at the same hospital does not get the benefit. The window closed on 26.05.2024, so for any later year a renewal order must be seen before the exemption is claimed. Check also that the treatment was at the approved premises, and keep the bills, since the relief follows expenditure actually incurred.

The Board’s own words

One sentence from the document itself, reproduced as the Board wrote it. Everything else on this page is our writing about it.

This approval is not transferable and is applicable only to the premises occupied by the hospital

— the Central Board of Direct Taxes, order, 31 May 2021. Read it in the department’s own PDF.

The provisions it turns on

The sections are the ones the document itself works on. Which section of the Income-tax Act, 2025 covers the same ground is the department’s own concordance and not our reading of it.
Under the Income-tax Act, 1961Now, in the Income-tax Act, 2025
section 17section 16, section 17, section 18
section 15section 15
section 16section 19

Cases in this library on the same provision

These decisions turn on the same provision of the 1961 Act that this document works on. They are about the provision, not about this document: none of them is authority on what the Board meant, and a court is in any event free to read the section for itself.

What here is the Board’s and what is ours. The document is the Central Board of Direct Taxes’ own. Its date and the words quoted above are reproduced from the Board’s own PDF, which is here. Everything else on this page is ours: the plain-English account of what the document is and what it does, the reading of which provision it turns on, the note on what to watch, and the choice of cases. Where our account and the document part, the document governs.

An order of the Board binds the department, not you and not a court. The Board writes to its own officers. An assessee may hold the department to an order or an instruction that helps him; the department cannot hold an assessee to one that hurts him, and the Tribunal and the courts decide the law for themselves. This is the most common mistake made with this material, and it is worth making twice: a direction of the Board is not a section of the Act.

We did not read all of it. The department’s file returned only part of this document to us, so what is written above is written from the part we could read. Open the PDF before you rely on it.

What we could not settle. This is a Principal Chief Commissioner's order, not a Board order. The signature-block date and the DIN are garbled in the scan, so the date has been taken from the department's own listing (31.05.2021); the order itself states that it takes effect from 27.05.2021. Paragraph 3, on tax deduction at source, is cut off mid-sentence in the scan and the section number reads as '!97' - it cannot be said from the text whether section 192 or section 197 is meant, and no number has been supplied. Much of the body is heavily garbled by OCR, which is why only a short passage has been quoted.