Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Medical relief by a registered charitable hospital remains within the charitable-purpose limb even where treatment charges are received through insurers or third-party administrators; such receipts are a payment mechanism and do not show service to a restricted class. The proviso for advancement of general public utility is therefore inapplicable, supporting exemption under section 11 rather than taxation of surplus as business income. Audited books alone do not establish expenditure claims where supporting bills and vouchers are unavailable, although reasonable opportunity to submit evidence may justify fresh adjudication. Tax deduction at source disallowances require verification of ledgers, bank records, returns and challans where compliance evidence has not been examined.
Medical relief by a registered charitable hospital remains within the charitable-purpose limb even where treatment charges are received through insurers or third-party administrators; such receipts are a payment mechanism and do not show service to a restricted class. The proviso for advancement of general public utility is therefore inapplicable, supporting exemption under section 11 rather than taxation of surplus as business income. Audited books alone do not establish expenditure claims where supporting bills and vouchers are unavailable, although reasonable opportunity to submit evidence may justify fresh adjudication. Tax deduction at source disallowances require verification of ledgers, bank records, returns and challans where compliance evidence has not been examined.
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