Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
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Approval under section 10(23C)(via) depends on whether a hospital exists solely for philanthropic purposes and not for profit. Financial position should account for capital expenditure on medical equipment and facilities, actual application of funds, and depreciation, rather than excess receipts over revenue expenditure alone. Capital application and depreciation have distinct functions. Consultant-fee arrangements do not alone show profit distribution where retained sums pay for hospital facilities and services. Medical relief to paying patients may be philanthropic; no minimum ratio of free or concessional treatment is prescribed. Philanthropic character depends on objects, medical activities, application of income and assets, charitable-hospital obligations, and absence of unrelated commercial activity or private diversion.
Approval under section 10(23C)(via) depends on whether a hospital exists solely for philanthropic purposes and not for profit. Financial position should account for capital expenditure on medical equipment and facilities, actual application of funds, and depreciation, rather than excess receipts over revenue expenditure alone. Capital application and depreciation have distinct functions. Consultant-fee arrangements do not alone show profit distribution where retained sums pay for hospital facilities and services. Medical relief to paying patients may be philanthropic; no minimum ratio of free or concessional treatment is prescribed. Philanthropic character depends on objects, medical activities, application of income and assets, charitable-hospital obligations, and absence of unrelated commercial activity or private diversion.
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