Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Exemption u/s 11 for surplus arising from a pharmacy store run by a hospital, and the deduction of 15% on gross receipts u/s 11(1)(a). Regarding the pharmacy store, it was held that running a pharmacy is incidental to the main objects of running a hospital and research center, and hence not hit by Section 11(4A). The pharmacy store serves only admitted patients, not outsiders, and is an integral part of the assessee's activities. This issue was already decided in the assessee's favor by the ITAT and the jurisdictional High Court. Concerning the deduction u/s 11(1)(a), it was held that the assessee is entitled to claim a deduction of 15% on gross receipts, as per the Supreme Court's decision in Programme for Community Organisation. The deduction is to be calculated on gross receipts and not on surplus or deficit, without any condition imposed by Section 11(1)(a).
Exemption u/s 11 for surplus arising from a pharmacy store run by a hospital, and the deduction of 15% on gross receipts u/s 11(1)(a). Regarding the pharmacy store, it was held that running a pharmacy is incidental to the main objects of running a hospital and research center, and hence not hit by Section 11(4A). The pharmacy store serves only admitted patients, not outsiders, and is an integral part of the assessee's activities. This issue was already decided in the assessee's favor by the ITAT and the jurisdictional High Court. Concerning the deduction u/s 11(1)(a), it was held that the assessee is entitled to claim a deduction of 15% on gross receipts, as per the Supreme Court's decision in Programme for Community Organisation. The deduction is to be calculated on gross receipts and not on surplus or deficit, without any condition imposed by Section 11(1)(a).
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