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...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
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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Medicines and consumables supplied by a hospital pharmacy to in-patients during diagnosis or treatment are treated as part of a composite supply of healthcare services, not as separate retail sales. The Authority states that in-patient care includes the full bundle of medical, pharmaceutical, paramedical, nursing, laboratory and allied services from admission to discharge, and that such supplies are naturally bundled with the principal healthcare service in the ordinary course of business. Applying section 8(a), the composite supply assumes the character of healthcare services and is exempt under Entry 74 of Notification No. 12/2017-C.T. (Rate); the circular on in-patient healthcare was also relied on as supporting this treatment.
Medicines and consumables supplied by a hospital pharmacy to in-patients during diagnosis or treatment are treated as part of a composite supply of healthcare services, not as separate retail sales. The Authority states that in-patient care includes the full bundle of medical, pharmaceutical, paramedical, nursing, laboratory and allied services from admission to discharge, and that such supplies are naturally bundled with the principal healthcare service in the ordinary course of business. Applying section 8(a), the composite supply assumes the character of healthcare services and is exempt under Entry 74 of Notification No. 12/2017-C.T. (Rate); the circular on in-patient healthcare was also relied on as supporting this treatment.
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