Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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