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Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
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Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Sections 92A(1) and 92A(2) require a harmonious reading: the statutory circumstances in section 92A(2), including business dependence under section 92A(2)(g), do not independently establish an associated-enterprise relationship without participation in management, control or capital under section 92A(1). Commercial dependence or distribution exclusivity alone is insufficient absent evidence of ownership, voting rights, managerial participation or financial control. For internal CUP analysis, contractual differences do not disqualify an uncontrolled transaction unless they materially affect the royalty rate and cannot be eliminated through reasonably accurate, objectively verifiable adjustments. Royalty benchmarking was remanded to examine those differences and adjustments; if CUP is unreliable, the most appropriate method must be independently selected.
Sections 92A(1) and 92A(2) require a harmonious reading: the statutory circumstances in section 92A(2), including business dependence under section 92A(2)(g), do not independently establish an associated-enterprise relationship without participation in management, control or capital under section 92A(1). Commercial dependence or distribution exclusivity alone is insufficient absent evidence of ownership, voting rights, managerial participation or financial control. For internal CUP analysis, contractual differences do not disqualify an uncontrolled transaction unless they materially affect the royalty rate and cannot be eliminated through reasonably accurate, objectively verifiable adjustments. Royalty benchmarking was remanded to examine those differences and adjustments; if CUP is unreliable, the most appropriate method must be independently selected.
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