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...
For Section 44B, "carriage" of passengers by a foreign shipping enterprise extends beyond transportation between two ports. A round cruise voyage may remain passenger carriage where passengers can disembark at intermediate ports and the principal receipts arise from cabin and transport fares. On-board hospitality and entertainment are ancillary to the voyage and do not, by themselves, remove cruise operations from the presumptive taxation scheme. The text states that the non-resident cruise operator's income was therefore computable under Section 44B at the prescribed presumptive rate, and the concurrent finding treating the activity as passenger carriage was affirmed.
For Section 44B, "carriage" of passengers by a foreign shipping enterprise extends beyond transportation between two ports. A round cruise voyage may remain passenger carriage where passengers can disembark at intermediate ports and the principal receipts arise from cabin and transport fares. On-board hospitality and entertainment are ancillary to the voyage and do not, by themselves, remove cruise operations from the presumptive taxation scheme. The text states that the non-resident cruise operator's income was therefore computable under Section 44B at the prescribed presumptive rate, and the concurrent finding treating the activity as passenger carriage was affirmed.
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