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...
Taxation of a trust created under a Will turned on the principle of consistency: where the Department had accepted the same Will and Indenture of Declaration of Trust in a subsequent year, and there was no change in facts or law, the Revenue could not take a contrary stand for the year in issue. The Tribunal also held that its appellate powers were not confined by rectification limits and that correct tax liability could be determined on the material before it. The CIT(A)'s order was set aside and the AO was directed to apply the individual rate, subject to verification that the trust was the same trust earlier accepted, with consequential interest recomputation.
Taxation of a trust created under a Will turned on the principle of consistency: where the Department had accepted the same Will and Indenture of Declaration of Trust in a subsequent year, and there was no change in facts or law, the Revenue could not take a contrary stand for the year in issue. The Tribunal also held that its appellate powers were not confined by rectification limits and that correct tax liability could be determined on the material before it. The CIT(A)'s order was set aside and the AO was directed to apply the individual rate, subject to verification that the trust was the same trust earlier accepted, with consequential interest recomputation.
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