Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
AAR ruled that the applicant's cancer diagnostic services do not qualify for GST exemption under Notification No. 12/2017-CT(R). The tests were determined to be clinical research and experimental development, primarily focused on acquiring new knowledge in biotechnology and cancer prognostic technologies. Without proper licensing from CDSCO or ICMR, the services were classified under Service Accounting Code 9981 for research services, rendering them ineligible for tax exemption. The determination hinged on the nature of the service being research-oriented rather than a direct diagnostic healthcare service.
AAR ruled that the applicant's cancer diagnostic services do not qualify for GST exemption under Notification No. 12/2017-CT(R). The tests were determined to be clinical research and experimental development, primarily focused on acquiring new knowledge in biotechnology and cancer prognostic technologies. Without proper licensing from CDSCO or ICMR, the services were classified under Service Accounting Code 9981 for research services, rendering them ineligible for tax exemption. The determination hinged on the nature of the service being research-oriented rather than a direct diagnostic healthcare service.
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