Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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.
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