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...
Strict construction of exemption notifications barred astronomy coaching from the recreational activities exemption in Entry 8 of Notification No. 25/2012-ST, because the word "culture" was read in context with arts and sports under noscitur a sociis and could not be stretched to scientific training. The Tribunal therefore upheld denial of exemption and sustained the demand on merits. It also held that non-registration, non-filing of returns, and long-term commercial conduct amounted to suppression of material facts, so the extended period, interest, and penalty were justified. Cum-tax benefit under section 67(2) was allowed, but only for limited recomputation of the demand.
Strict construction of exemption notifications barred astronomy coaching from the recreational activities exemption in Entry 8 of Notification No. 25/2012-ST, because the word "culture" was read in context with arts and sports under noscitur a sociis and could not be stretched to scientific training. The Tribunal therefore upheld denial of exemption and sustained the demand on merits. It also held that non-registration, non-filing of returns, and long-term commercial conduct amounted to suppression of material facts, so the extended period, interest, and penalty were justified. Cum-tax benefit under section 67(2) was allowed, but only for limited recomputation of the demand.
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