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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The Appellate Tribunal concurred with the Mumbai Tribunal's order in M/s Pooja Marketing, which comprehensively dealt with all aspects, facts, and applicable case laws. The bench not only considered the validity of revisionary jurisdiction u/s 263 but also decided the issue on merits in favor of the assessee. The case law in CIT vs. Dr. M.A.M. Ramaswamy was distinguished by the learned Senior Counsel in written submissions, which was deliberated upon and found concurrence. No distinguishing feature or reversal of the Mumbai Tribunal's decision by higher judicial authorities was shown. The Tribunal dismissed the revenue's appeal after elaborately dealing with the issue on merits.
The Appellate Tribunal concurred with the Mumbai Tribunal's order in M/s Pooja Marketing, which comprehensively dealt with all aspects, facts, and applicable case laws. The bench not only considered the validity of revisionary jurisdiction u/s 263 but also decided the issue on merits in favor of the assessee. The case law in CIT vs. Dr. M.A.M. Ramaswamy was distinguished by the learned Senior Counsel in written submissions, which was deliberated upon and found concurrence. No distinguishing feature or reversal of the Mumbai Tribunal's decision by higher judicial authorities was shown. The Tribunal dismissed the revenue's appeal after elaborately dealing with the issue on merits.
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