Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Medical relief remains a distinct charitable purpose under section 12AB, and a hospital does not lose that character merely because it operates modern infrastructure, charges differential tariffs, serves paying patients or earns surplus, absent evidence of private enrichment, diversion of income, abandonment of objects, or use of funds for non-charitable purposes. For refusal or cancellation based on compliance with other laws, there must be an established breach determined by the competent authority; the income-tax authority cannot itself adjudicate alleged violations of the Maharashtra Public Trusts Act or the IPF Scheme. On that basis, retrospective cancellation and the consequential refusal of related approval were unsustainable.
Medical relief remains a distinct charitable purpose under section 12AB, and a hospital does not lose that character merely because it operates modern infrastructure, charges differential tariffs, serves paying patients or earns surplus, absent evidence of private enrichment, diversion of income, abandonment of objects, or use of funds for non-charitable purposes. For refusal or cancellation based on compliance with other laws, there must be an established breach determined by the competent authority; the income-tax authority cannot itself adjudicate alleged violations of the Maharashtra Public Trusts Act or the IPF Scheme. On that basis, retrospective cancellation and the consequential refusal of related approval were unsustainable.
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