Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Operation and management of Government health centres and polyclinics under a contractual arrangement with a PSU executing agency was treated as a taxable supply of contractual operational and managerial services. Entry 74 exemption for healthcare services by a clinical establishment was denied because the applicant itself was not supplying healthcare as the clinical establishment, and the payments were linked to centre-wise operational obligations rather than diagnosis or treatment. Entry 3 exemption for pure services was also unavailable because the supply was made to the PSU, not directly to Government, and the arrangement was composite rather than pure services. Receipts were characterised as contractual consideration, not grant or subsidy.
Operation and management of Government health centres and polyclinics under a contractual arrangement with a PSU executing agency was treated as a taxable supply of contractual operational and managerial services. Entry 74 exemption for healthcare services by a clinical establishment was denied because the applicant itself was not supplying healthcare as the clinical establishment, and the payments were linked to centre-wise operational obligations rather than diagnosis or treatment. Entry 3 exemption for pure services was also unavailable because the supply was made to the PSU, not directly to Government, and the arrangement was composite rather than pure services. Receipts were characterised as contractual consideration, not grant or subsidy.
Note: It is a system-generated summary and is for quick reference only.