Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ayurvedic therapeutic treatment provided through a licensed hospital was held to fall outside the taxable category of Health and Fitness Services, because the records showed diagnosis, treatment and supervision by qualified medical practitioners using recognised Ayurvedic procedures, and the Revenue produced no contrary evidence. The pre-01.07.2012 demand was therefore unsustainable. For the post-01.07.2012 period, the Tribunal held that the appellant functioned as a clinical establishment rendering health care services in a recognised system of medicine, so the exemption under Notification No. 25/2012-ST applied. The post-01.07.2012 demands were accordingly not maintainable and the impugned orders were set aside.
Ayurvedic therapeutic treatment provided through a licensed hospital was held to fall outside the taxable category of Health and Fitness Services, because the records showed diagnosis, treatment and supervision by qualified medical practitioners using recognised Ayurvedic procedures, and the Revenue produced no contrary evidence. The pre-01.07.2012 demand was therefore unsustainable. For the post-01.07.2012 period, the Tribunal held that the appellant functioned as a clinical establishment rendering health care services in a recognised system of medicine, so the exemption under Notification No. 25/2012-ST applied. The post-01.07.2012 demands were accordingly not maintainable and the impugned orders were set aside.
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