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...
Tax treatment of bundled hospital charges was assessed: supplies to in patients (room, tests, medicines, consumables and care) constitute a composite supply with healthcare services as the principal supply under Section 2(30). Consequently the composite transaction is classifiable as inpatient health care and falls within the exemption scope of SI. No.74 read with section 8(a), but the proviso excludes exemption for room charges (other than ICU/CCU) when room rent exceeds Rs. 5,000 per day; such excess room rent is taxable even though other components remain exempt.
Tax treatment of bundled hospital charges was assessed: supplies to in patients (room, tests, medicines, consumables and care) constitute a composite supply with healthcare services as the principal supply under Section 2(30). Consequently the composite transaction is classifiable as inpatient health care and falls within the exemption scope of SI. No.74 read with section 8(a), but the proviso excludes exemption for room charges (other than ICU/CCU) when room rent exceeds Rs. 5,000 per day; such excess room rent is taxable even though other components remain exempt.
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