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...
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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