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...
Article 289(1) immunises the property and income of a State from Union taxation, overriding an inconsistent charge under the Income-tax Act. A State-controlled conservation society, governed and staffed by State functionaries, financially and functionally dependent on the State, and discharging environmental conservation obligations linked to Article 48A, falls within State instrumentality principles. Statutory, ring-fenced conservation funds and incidental interest constitute public funds held in trust rather than ordinary commercial receipts. Such income cannot be charged to tax, and tax-recovery action lacks jurisdiction. Bank-account attachment for recovery under the Income-tax Act was therefore unsustainable and quashed.
Article 289(1) immunises the property and income of a State from Union taxation, overriding an inconsistent charge under the Income-tax Act. A State-controlled conservation society, governed and staffed by State functionaries, financially and functionally dependent on the State, and discharging environmental conservation obligations linked to Article 48A, falls within State instrumentality principles. Statutory, ring-fenced conservation funds and incidental interest constitute public funds held in trust rather than ordinary commercial receipts. Such income cannot be charged to tax, and tax-recovery action lacks jurisdiction. Bank-account attachment for recovery under the Income-tax Act was therefore unsustainable and quashed.
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