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...
Healthcare services supplied by a clinical establishment through doctors, specialists and para-medical personnel were held exempt under Notification No. 12/2017-Central Tax (Rate) read with the CBIC circular, because the substance of the arrangement was direct diagnosis, treatment and medical care to patients. The revenue-sharing structure did not convert the service into manpower supply or business support, and classification under SAC 9985 was rejected. The show cause notices seeking GST on exempt healthcare services were without jurisdiction and were quashed. The writ petitions were maintainable despite the alternative remedy objection because the notices proceeded on an erroneous denial of exemption and the foundational jurisdictional facts were absent.
Healthcare services supplied by a clinical establishment through doctors, specialists and para-medical personnel were held exempt under Notification No. 12/2017-Central Tax (Rate) read with the CBIC circular, because the substance of the arrangement was direct diagnosis, treatment and medical care to patients. The revenue-sharing structure did not convert the service into manpower supply or business support, and classification under SAC 9985 was rejected. The show cause notices seeking GST on exempt healthcare services were without jurisdiction and were quashed. The writ petitions were maintainable despite the alternative remedy objection because the notices proceeded on an erroneous denial of exemption and the foundational jurisdictional facts were absent.
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