Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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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