Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
AAR determined that services provided to 54 government hospitals under DM&RHS constitute exempt supplies. The ruling hinged on constitutional provisions under Articles 243G and 243W, which define public health and hospital services as state government responsibilities. The services, including housekeeping, security, and maintenance support, directly relate to hospital facility operations. Consequently, these services fall under Entry No.3 of Notification No. 12/2017-CT (Rate), rendering them tax exempt. The exemption applies specifically to activities intrinsically linked to public health infrastructure maintenance, recognizing the essential nature of supporting government healthcare facilities.
AAR determined that services provided to 54 government hospitals under DM&RHS constitute exempt supplies. The ruling hinged on constitutional provisions under Articles 243G and 243W, which define public health and hospital services as state government responsibilities. The services, including housekeeping, security, and maintenance support, directly relate to hospital facility operations. Consequently, these services fall under Entry No.3 of Notification No. 12/2017-CT (Rate), rendering them tax exempt. The exemption applies specifically to activities intrinsically linked to public health infrastructure maintenance, recognizing the essential nature of supporting government healthcare facilities.
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