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Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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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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