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...
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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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ITAT ruled that pharmacy division income of appellant hospital qualifies for exemption under Section 11(1) of Income Tax Act. The tribunal determined pharmacy operations were integral to hospital's dominant charitable purpose, not a separate business activity requiring distinct accounting under Section 11(4A). Following precedent in Jaslok Hospital case, ITAT found pharmacy services essential for both inpatient care and OPD treatment, directly supporting hospital's philanthropic objectives. The surplus from pharmacy operations was utilized for trust's charitable purposes. Accordingly, ITAT directed deletion of AO's addition, maintaining hospital's tax-exempt status for pharmacy division income.
ITAT ruled that pharmacy division income of appellant hospital qualifies for exemption under Section 11(1) of Income Tax Act. The tribunal determined pharmacy operations were integral to hospital's dominant charitable purpose, not a separate business activity requiring distinct accounting under Section 11(4A). Following precedent in Jaslok Hospital case, ITAT found pharmacy services essential for both inpatient care and OPD treatment, directly supporting hospital's philanthropic objectives. The surplus from pharmacy operations was utilized for trust's charitable purposes. Accordingly, ITAT directed deletion of AO's addition, maintaining hospital's tax-exempt status for pharmacy division income.
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