Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Actual and continuous agricultural operations are not a mandatory statutory condition under section 2(14)(iii) where land is agricultural in character and lies beyond prescribed municipal limits. The ITAT noted that this provision follows an objective test based on municipal limits, population and urban proximity, unlike sections 54B and 10(37), and that actual cultivation is only an evidentiary factor, not the sole or independent test. On the facts, the land remained agricultural in records, was outside municipal limits and a no-development zone, and the capital gains addition was deleted.
Actual and continuous agricultural operations are not a mandatory statutory condition under section 2(14)(iii) where land is agricultural in character and lies beyond prescribed municipal limits. The ITAT noted that this provision follows an objective test based on municipal limits, population and urban proximity, unlike sections 54B and 10(37), and that actual cultivation is only an evidentiary factor, not the sole or independent test. On the facts, the land remained agricultural in records, was outside municipal limits and a no-development zone, and the capital gains addition was deleted.
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