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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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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