Aster DM Healthcare Ltd

As a part of internal capital restructuring the Company, a loan of Rs.129.35 Cr extended by the Company to AMHPL has been converted into equity shares and accordinlgy issued 12,93,45,537 equity shares of face value Rs.10 each to the Company on 27 March 2026. No change in shareholding. The Company continues to hold 100% in the equity share capital of AMHPL.

Considering the immateriality of the amount involved and the facts of the case, the Company, based on careful assessment, decided not to pursue further appellate proceedings. Accordingly, the matter stands concluded.

Company claimed deduction of INR 2,96,353 while filing ITR. After filing the ITR, return was selected for scrutiny and notice u/s 142(1) was issued on 10th May 2011 requiring the Company to produce relevant books of accounts. Thereafter, another notice was issued on 22nd Sep 2011 and in response to the same, Company's authorised representative (A.R.) Shri R. Ganesh appeared before the department and case was discussed with him. During the course of hearing, details were sought for the deduction of INR 28,090 which were not submitted in stipulated time owing to which Department issued the Assessment order by making said disallowance and adjusting the same with losses reported in the return.

The company received the order u/s 143(3) on 30th Dec 2019 making disallowance under Section 14A,. 35AD and 36(1)(va). The Company filed appeal against the said disallowance with CIT(A) on 21st Jan 2020 stating that company has already considered all the proposed disallowance. Disallowing the same again will result in double tax impact. The Assessment order was set aside by PCIT pursuant to order u/s 263 and accordingly CIT(A) stated that the appeal also stands null and void and accordingly dismissed the appeal Recently, Company received the Show cause Notice dated 18th March 2026 initiating penalty against the assessment order passed on 30th Dec 2019. The Company filed a detailed reply on 1st April 2026 stating that the assessment order has been set aside by PCIT and appeal has been disposed of as null and void and therefore the penalty proceedings against the assessment order dated 30th Dec 2019 is infructuous and has to be dropped.

The company has received the order u/s 143(3) r.w.s. 263 of Income tax Act on 13th March 2023 stated that payment related to EPF and PF amounting to INR 62,68,644 made after due date as specified under labour Acts. The Company has filed appeal against the said disallowance on 31st March 23 stated that delay in contribution is account of technical difficulties in the portal on account of ESI and EPF portal migration and there was no intention to make the remittance after the due date.

The company received notice u/s 143(3) on 24th March 2021 stating that Company has not disallowed the expenditure incurred for earning exempt income u/s 14A amounting to INR 5,84,34,120 and accordingly, the same was disallowed in the order Company filed the appeal against the disallowance with CIT(Appeal) stating that the disallowance made is not appropriate as company has Suo moto disallowed the expense under section 14A r.w.r 8D. The Assessment order was set aside by PCIT pursuant to order u/s 263 and accordingly CIT(A) stated that the appeal also stands null and void and accordingly dismissed the appeal Recently, the company received a show cause notice under Section 270A for AY 2018–19 on 10th Feb 2026 initiating penalty against the assessment order dated 24th March 2021. The Company filed a detailed reply on 12th Feb 2026 stating that the assessment order has been set aside by PCIT and appeal has been disposed of as null and void and therefore the penalty proceedings against the assessment order dated 24th Mar 2021 is infructuous and has to be dropped.

The company has received order u/s 143(3) on 30th March 24 which states that IPO proceeds are not utilised for the purpose for which it raised and hence share issue expense shall be disallowed. The Company is of the view that, even though IPO proceeds were utilised for repayment of loan, the end utilisation of the loan was towards expansion of Hospitals. Company has filed the appeal against the disallowance made at CIT(Appeal) authority level on 15th April 24 stated that the loan taken by the Company was towards expansion of the aforesaid hospitals.

The company received multiple notices (u/s 142(1) and 143(2)) between June 2021 and July 2023 requesting documents for the return of income, which were submitted. On 26th Sep 2023, an order u/s 143(3) was issued disallowing INR 5,79,46,823 under section 14A. The company appealed on 10th Oct 2023, stating that the disallowance was unnecessary as it had already Suo-motu disallowed the expense under section 14A r.w.r 8D. Notice issued u/s 263 dated 26th December 2025 required company to represent before the department on 7th January 2026 in person or via authorised representative in relation to Sec 14A disallowance etc. which was attended personally scheduled at Kochi DGGI office on 7th January 2026 at 3:30 PM by Company's Tax consultant. The Assessment order was set aside by PCIT pursuant to order u/s 263 and accordingly CIT(A) stated that the appeal also stands null and void and accordingly dismissed the appeal Recently, Company received Penalty order dated 18th March 2026 against disallowance made in the assessment order dated 26th Sep 2023 having a demand of INR 1.06 Crores against which company has filed an appeal with CIT(A). It submits that the penalty is based on an assessment order dated 26.09.2023, which was subsequently set aside by the Principal Chief Commissioner of Income Tax under Section 263 on 05.03.2026 for fresh assessment. Since the underlying assessment order no longer exists, the penalty demand is a mistake apparent on record and has become infructuous. Accordingly, the company has requested that the penalty of INR 1.06 crore be quashed.

Department has stated that company has not disallowed expenditure pertaining to INR 75.83 Crores pertaining to ICDS Disclosure, Sec 43B, Sec 23 of MSME etc. and raised demand amounting to INR 14.79 Crores. Company has filed an detailed response against the said demand on 14th Dec 2022. Further department has passed the rectification order nullifying the demand to Nil on 19th Feb 2025.

The company received intimation u/s 142(1) on 4th July 2023, 24th Dec 2023, and 1st Mar 2024, requesting documents, which were provided. On 22nd March 2024, a notice u/s 143(3) was issued, stating non-disallowance of INR 1,12,89,25,899 related to ICDS disclosure, Sec 43B, and Sec 40A(7), resulting in an IT demand of INR 36,02,08,230. The company filed a rectification application on 24th April 2024, citing disclosure differences. Further department has passed the rectification order nullifying the demand to Nil on 25th Feb 2025.

On 6th Dec 2023, the department issued a notice proposing a disallowance of INR 1,13,09,336 u/s 143(1)(a). The proposed adjustments included: a) INR 36,569 for employee contributions to welfare funds under section 36(1)(va), which the company stated had already been disallowed in the return of income filed. b) INR 1,12,72,767 for gratuity provision under section 40A(7), which the company also claimed was included in the total disallowance as per filed return. The company disagreed with the proposed adjustments, stating they had already been addressed. The response was duly accepted and intimation 143(1) was issued without any adjustments

The department has issued penalty show cause notice stated that company has not disallowed the Share issues expenses incurred on account of IPO issued. Management has filed the response against the said SCN on 22nd May 2024 stated that expenditure incurred by the Company are in the nature of underwriting commission, brokerage and charges for drafting, typing, printing and advertisement of the prospectus which qualify to claim u/s 35AD. Hence, penalty proceeding shall not be initiated till the disposal of appeal preferred against CIT(Appeal).

Notice required the company to provide the summary of transaction entered with Mr. Hameed and relevant bank statement, ledger account and total fees paid to Assessee to support these transactions by 24th Dec 2024. Company has responded to the above notice by responding over the mail on 7th Jan 2025

After due consideration of the merits and materiality, the Company elected not to file an appeal. The matter has attained finality.

Company claimed loss of INR 2,63,44,28 while filing ITR. After filing the ITR, return was selected for scrutiny and notice u/s 142(1) was issued on 19th March 2013 requiring the Company to produce relevant books of accounts along with details of the total expenses of INR 4,19,64,645 Furthermore, the department contended that the expenditure relating to exempt income should be disallowed to the extent of INR 15,59,203 The Company submitted the requested details on 28th June 2013, indicating that out of the total expenses of INR 4,19,64,645, INR 1,41,13,678 was incurred for consultancy assignments, INR 6,49,753 for the Kochi Medcity project, and INR 2,72,01,213 for common expenses. However, the department took the view that the expenditure related to the Kochi Medcity project (INR 6,49,753) and 10% of the common expenses (pertaining to the project) amounting to INR 33,69,874 should be disallowed and capitalized. Regarding 14A disallowed, the Company has already disallowed the expenditure incurred for earning dividend income, amounting to INR 2,11,695. Accordingly, additional expenditure of INR 13,47,508 was disallowed. Assessment order was passed by making these two additions

Notice issued for Sec. 142(1) dated 20th Dec 2024 to produce certain books of account. Company has submitted the required set of documents as asked in Income Tax portal on 6th Jan 2025.

Notice required the company to provide the details of payment made to Mr. Sumon Khan along with invoice and mode of payment. Company has responded to the above notice by responding over the mail on 21st Jan 2025.

Notice served in IT portal on 27th Dec 2024 for proposed ICDS adjustment made in ITR filed for FY 23-24. Company has submitted the responses on 3rd Jan 2025 stating that all proposed adjustment has already been made and hence making the adjustment again will have twice impact.

Notice required the company to provide the details of contract and rent payment made to Mr. TIJO TOMY CHIRAKARA along with agreement entered and ledger of the above mentioned Assessee and mode of payment. Further, company was not able to file the response since there was no path mentioned in the notice regarding the submission even though company is ready with all the required set of documents. Further, we have raised grievance issue also regarding the same on that day.

Company has received intimation u/s 143(1) on 5th June 2025 where department is of the contention that there is difference in TDS credit available as per 26AS and TDS credit availed while filing ITR for FY 23-24.

Department has issued notice stating that since the appeal has been filed for subsequent proceeding and order passed u/s 263 hence appeal filed against first proceeding shall stand void.

Notice issued to the company to provide the nature of technical or professional service rendered by Assessee named Mr.Rangenahalli Udayakumar Divya along with agreement entered and ledger of the above mentioned Assessee and bank statement and copy of ITR.

Notice issued to the company to provide the nature of transaction or service rendered by Assessee named Mrs. Preetha Prakash Naik along with details of TDS deducted and mode of payment and copy of agreement and ledger of the above mentioned Assessee.

Mr. Ganesh from Rangamani & Co. who is Tax consultant of the group had attended the personal hearing scheduled at Kochi DGGI office on 7th January 2026 at 3:30 PM.

Notice issued u/s 263 dated 26th December 2025 required company to represent before the department on 7th January 2026 in person or via authorised representative in relation to ICDS disclosure, Sec 43B, and Sec 40A(7)

After due consideration of the merits and materiality, the Company elected not to file an appeal. The matter has attained finality.

The department issued a notice to the Company , stating that the return of income initially declared with a loss of INR 7,46,38,662 was revised to INR 7,33,26,546. The return was selected for scrutiny, and A.R. Shri R. Ganesh submitted the required details in person. The company earned consultancy, interest, and dividend income while developing the Kochi Medcity project. The department issued order u/s 143(3) on 24th March 2015and disallowed INR 10,05,637 for the project and 10% of common expenses (INR 72,74,942), directing these to be capitalized. Additionally, INR 39,40,093 related to exempt income (dividend and interest) was disallowed under Section 14A read with Rule 8D.

Notice issued u/s 92CA(2) dated 13th March 2026 required the company to produce details related to international transaction such as TPO order, Form 3CEB etc. against which the Company has filed the response on 9th April 2026

Proceedings under Section 201 were initiated, wherein the department sought details such as financial statements, tax audit report, TDS returns, and classification of doctor payouts under Sections 192 vs 194J. The matter was discussed with the CIT (TDS), who raised queries on the nature of transactions and differences between tax audit and financials, all of which were satisfactorily explained. The CIT(TDS) accepted the submissions and issued a Nil demand order on 17th March 2026

The Company has adopted a view that payment to doctors is liable to TDS under section 194J of the Act on account of the following : a) No employment contract with the Doctors b) Doctors are not entitled to employee benefits as per contract and expressly mentioned in the agreement that there is no employer employee relationship c) No prohibition/ bar on the doctors to be associated with other hospitals. d) No restriction on the nature of work that doctors perform in Aster DM e) Aster DM exercises no disciplinary control over doctors f) Contract with doctors is a Contract for service and not contract of service In a similar case in Manipal Health Systems Ltd vs CIT (Karnataka High Court (2015) reported in ITANO.747/2009 c/w ITA NO. 746/2009, the Karnataka High Court observed that contract between the Assessee and doctors was not a Contract of Service but Contract for service and therefore the payments made to doctors by the hospital are covered under section 194J. Given the above and review of submissions filed supported by multiple judicial precedents, a view may be adopted that the Company shall deduct TDS on payment to doctors under section 194J of the Act considering that primarily, there is no employer-employee relationship along with other grounds as given by the Company. Further company has filed appeal with the CIT(A) with respect to the said demand raised and paid 20% of the demand amount as we want to obtained LDC and department insisted us to pay that amount in order to provide LDC. Further, company has received favourable order from CIT(A) for AY 2018-19, 2019-20, 2020-21 and 2021-22 on 24th Dec 2024 stating that TDS deducted u/s 194J is appropriate and raised demand has been dropped. Accordingly company is eligible for refund amount for the amount which they already paid. Further, Company has received notice from the ITAT where they required management to appear for personal hearing at Kochi office. The hearing was attended by Mr. Krishnan (Senior Partner) of Rangamani & Co.

The Company has adopted a view that payment to doctors is liable to TDS under section 194J of the Act on account of the following : a) No employment contract with the Doctors b) Doctors are not entitled to employee benefits as per contract and expressly mentioned in the agreement that there is no employer employee relationship c) No prohibition/ bar on the doctors to be associated with other hospitals. d) No restriction on the nature of work that doctors perform in Aster DM e) Aster DM exercises no disciplinary control over doctors f) Contract with doctors is a Contract for service and not contract of service In a similar case in Manipal Health Systems Ltd vs CIT (Karnataka High Court (2015) reported in ITANO.747/2009 c/w ITA NO. 746/2009, the Karnataka High Court observed that contract between the Assessee and doctors was not a Contract of Service but Contract for service and therefore the payments made to doctors by the hospital are covered under section 194J. Given the above and review of submissions filed supported by multiple judicial precedents, a view may be adopted that the Company shall deduct TDS on payment to doctors under section 194J of the Act considering that primarily, there is no employer-employee relationship along with other grounds as given by the Company. Further company has filed appeal with the CIT(A) with respect to the said demand raised and paid 20% of the demand amount as we want to obtained LDC and department insisted us to pay that amount in order to provide LDC. Further, company has received favourable order from CIT(A) for AY 2018-19, 2019-20, 2020-21 and 2021-22 on 24th Dec 2024 stating that TDS deducted u/s 194J is appropriate and raised demand has been dropped. Accordingly company is eligible for refund amount for the amount which they already paid. Further, Company has received notice from the ITAT where they required management to appear for personal hearing at Kochi office. The hearing was attended by Mr. Krishnan (Senior Partner) of Rangamani & Co.

The Company has adopted a view that payment to doctors is liable to TDS under section 194J of the Act on account of the following : a) No employment contract with the Doctors b) Doctors are not entitled to employee benefits as per contract and expressly mentioned in the agreement that there is no employer employee relationship c) No prohibition/ bar on the doctors to be associated with other hospitals. d) No restriction on the nature of work that doctors perform in Aster DM e) Aster DM exercises no disciplinary control over doctors f) Contract with doctors is a Contract for service and not contract of service In a similar case in Manipal Health Systems Ltd vs CIT (Karnataka High Court (2015) reported in ITANO.747/2009 c/w ITA NO. 746/2009, the Karnataka High Court observed that contract between the Assessee and doctors was not a Contract of Service but Contract for service and therefore the payments made to doctors by the hospital are covered under section 194J. Given the above and review of submissions filed supported by multiple judicial precedents, a view may be adopted that the Company shall deduct TDS on payment to doctors under section 194J of the Act considering that primarily, there is no employer-employee relationship along with other grounds as given by the Company. Further company has filed appeal with the CIT(A) with respect to the said demand raised and paid 20% of the demand amount as we want to obtained LDC and department insisted us to pay that amount in order to provide LDC. Further, company has received favourable order from CIT(A) for AY 2018-19, 2019-20, 2020-21 and 2021-22 on 24th Dec 2024 stating that TDS deducted u/s 194J is appropriate and raised demand has been dropped. Accordingly company is eligible for refund amount for the amount which they already paid. Further, Company has received notice from the ITAT where they required management to appear for personal hearing at Kochi office. The hearing was attended by Mr. Krishnan (Senior Partner) of Rangamani & Co.

The Company has adopted a view that payment to doctors is liable to TDS under section 194J of the Act on account of the following : a) No employment contract with the Doctors b) Doctors are not entitled to employee benefits as per contract and expressly mentioned in the agreement that there is no employer employee relationship c) No prohibition/ bar on the doctors to be associated with other hospitals. d) No restriction on the nature of work that doctors perform in Aster DM e) Aster DM exercises no disciplinary control over doctors f) Contract with doctors is a Contract for service and not contract of service In a similar case in Manipal Health Systems Ltd vs CIT (Karnataka High Court (2015) reported in ITANO.747/2009 c/w ITA NO. 746/2009, the Karnataka High Court observed that contract between the Assessee and doctors was not a Contract of Service but Contract for service and therefore the payments made to doctors by the hospital are covered under section 194J. Given the above and review of submissions filed supported by multiple judicial precedents, a view may be adopted that the Company shall deduct TDS on payment to doctors under section 194J of the Act considering that primarily, there is no employer-employee relationship along with other grounds as given by the Company. Further company has filed appeal with the CIT(A) with respect to the said demand raised and paid 20% of the demand amount as we want to obtained LDC and department insisted us to pay that amount in order to provide LDC. Further, company has received favourable order from CIT(A) for AY 2018-19, 2019-20, 2020-21 and 2021-22 on 24th Dec 2024 stating that TDS deducted u/s 194J is appropriate and raised demand has been dropped. Accordingly company is eligible for refund amount for the amount which they already paid. Further, Company has received notice from the ITAT where they required management to appear for personal hearing at Kochi office. The hearing was attended by Mr. Krishnan (Senior Partner) of Rangamani & Co.

The Company has adopted a view that payment to doctors is liable to TDS under section 194J of the Act on account of the following : a) No employment contract with the Doctors b) Doctors are not entitled to employee benefits as per contract and expressly mentioned in the agreement that there is no employer employee relationship c) No prohibition/ bar on the doctors to be associated with other hospitals. d) No restriction on the nature of work that doctors perform in Aster DM e) Aster DM exercises no disciplinary control over doctors f) Contract with doctors is a Contract for service and not contract of service In a similar case in Manipal Health Systems Ltd vs CIT (Karnataka High Court (2015) reported in ITANO.747/2009 c/w ITA NO. 746/2009, the Karnataka High Court observed that contract between the Assessee and doctors was not a Contract of Service but Contract for service and therefore the payments made to doctors by the hospital are covered under section 194J. Given the above and review of submissions filed supported by multiple judicial precedents, a view may be adopted that the Company shall deduct TDS on payment to doctors under section 194J of the Act considering that primarily, there is no employer-employee relationship along with other grounds as given by the Company. Further company has filed appeal with the CIT(A) with respect to the said demand raised and paid 20% of the demand amount as we want to obtained LDC and department insisted us to pay that amount in order to provide LDC. Further, company has received favourable order from CIT(A) for AY 2018-19, 2019-20, 2020-21 and 2021-22 on 24th Dec 2024 stating that TDS deducted u/s 194J is appropriate and raised demand has been dropped. Accordingly company is eligible for refund amount for the amount which they already paid. Further, Company has received notice from the ITAT where they required management to appear for personal hearing at Kochi office. The hearing was attended by Mr. Krishnan (Senior Partner) of Rangamani & Co.

The Company has adopted a view that payment to doctors is liable to TDS under section 194J of the Act on account of the following : a) No employment contract with the Doctors b) Doctors are not entitled to employee benefits as per contract and expressly mentioned in the agreement that there is no employer employee relationship c) No prohibition/ bar on the doctors to be associated with other hospitals. d) No restriction on the nature of work that doctors perform in Aster DM e) Aster DM exercises no disciplinary control over doctors f) Contract with doctors is a Contract for service and not contract of service In a similar case in Manipal Health Systems Ltd vs CIT (Karnataka High Court (2015) reported in ITANO.747/2009 c/w ITA NO. 746/2009, the Karnataka High Court observed that contract between the Assessee and doctors was not a Contract of Service but Contract for service and therefore the payments made to doctors by the hospital are covered under section 194J. Given the above and review of submissions filed supported by multiple judicial precedents, a view may be adopted that the Company shall deduct TDS on payment to doctors under section 194J of the Act considering that primarily, there is no employer-employee relationship along with other grounds as given by the Company. Further company has filed appeal with the CIT(A) with respect to the said demand raised and paid 20% of the demand amount as we want to obtained LDC and department insisted us to pay that amount in order to provide LDC. Further, company has received favourable order from CIT(A) for AY 2018-19, 2019-20, 2020-21 and 2021-22 on 24th Dec 2024 stating that TDS deducted u/s 194J is appropriate and raised demand has been dropped. Accordingly company is eligible for refund amount for the amount which they already paid. Further, Company has received notice from the ITAT where they required management to appear for personal hearing at Kochi office. The hearing was attended by Mr. Krishnan (Senior Partner) of Rangamani & Co.

The Income Tax Department issued a notice to the company on 18th June 2025, stating that the Company had reported 242 payments in the Tax Audit Report for FY 2018–19, wherein TDS amounting to INR 82.13 lakhs was not deducted. The Department has sought clarification on whether such payments were subsequently made or reversed in the following year. The company was scheduled to attend a personal hearing on 3rd July 2025.

ASMT-10 and DRC-01A issued with respect to difference in output tax liability declared in GSTR 1 and 3B return amounting to INR 19,09,920 The notices enquired about the reason for difference in output tax liability between GSTR 1 and GSTR 3B returns for the period FY 2022-23. Reply to the SCN filed by the Company online along with supporting documents on 18th July 2024 stated that there is only shortfall of INR 36,000 which has been paid along with interest amounting to INR 8,007 as applicable.

The department issued a notice under sections 143(3) and 147 of the Income Tax Act, disallowing legal and professional fees and business promotion expenses of INR 6,63,07,001, citing no business nexus with operational income. The company appealed, arguing: Re-assessment was invalid as all material facts were disclosed. The reassessment was a change of opinion, supported by a Supreme Court ruling. 10% of expenses had already been disallowed. Company has filed appeal against Commissioner of Income Tax(CIT) citing above reason.

Summon issued under section 70 of CGST Act, 2017 - Query with respect to IPO: The department has issued summon requiring necessary attendance for giving evidence and requesting to submit the following documents through personal attendance: 1. Details of IPO released by the Company 2. Value of IPO and date of release to the market 3. Details of ITC reversed by the company that has raised funds through initial public offering since April 2018. The Company filed a reply to the department vide letter dated 16th November 2023 with respect to ITC reversal on IPO expenses. The filed reply states that the Company has not utilized any ITC pertaining to IPO expenses and all those credits has been already reversed by the Company.

Summon issued under section 70 of CGST Act, 2017 - GST on Corporate Guarantee: The department has issued summon requiring personal attendance and requested to submit the certain set of document required as stated in the notice. The Company represented itself before the Department and have submitted preliminary information with respect to GST paid on Corporate Guarantee.

Company has filed the appeal against the Assistant Commissioner order on 14th June 2025. After filing the appeal, no further communication from the department.

SCN issued under Section 74 of CGST Act, 2017- GST on Covid vaccination The SCN enquired about non-payment of GST for covid vaccination. The SCN was issued to the Company as a whole (including Kerala registration). The company has filed response stated that we are not paying the amount since it is considered as healthcare service and should be treated as a composite supply to healthcare services. Further company has asked for personal hearing for issue and sent response on 8th of August 2024 via post. Further, company has received demand order on 19th March 2025 amounting to INR 1.08 Crores along with penalty amounting to 100%. Company has filed the appeal against the said demand on 14th June 2025 stating the facts to the GST Authority and paid 10% pre-deposit amount of demand raised to file the appeal to the Appellate authority. Also, the response has been filed offline at the GST office, Koramangala.

Form GST ADT - 01 notice issued for conducting department audit under Section 65 of CGST Act, 2017: The department has issued notice to produce certain document for initiation of Department audit like GSTR return working, RCM register etc. Further department has various set of document to complete the audit which has been produced by the company. Department has asked management to represent before the department. After representation, department has issued audit observation letter and raised demand of Rs. 69 lakhs against which company has responded. After responded against the audit observation letter, department has dropped the demand raised.

Summon issued by Tax authority on dated 25.11.2024 : Department has issued summon seeking information//documents/clarifications like sales and purchase register, GSTR 9 and 9C working, reconciliation of 1 vs 3b etc. for period between FY 2020-21 till FY 24-25. Company has represented before the tax authority physically on dated 30.11.2024 and provided the documents as required.

SCN notice issued on supply made to DM Medcity SEZ unit : Department has stated that supply made to SEZ will not be treated as Zero rated supply since no proper documentation maintained. Management has represented before the department on 18th Dec 24 and stated that supply made to SEZ unit should be treated as Zero rated supply and no GST payable on the same. Further we have LUT also for the year for supporting our view. Department has accepted the view and dropped the demand.

Company has filed the appeal to the higher authority against the order on 24th March 2025. No further update received from the concerned authority

Show Cause Notice issued by DGGI - GST on Accommodation provided to Bystanders: SCN alleges that Aster has not paid taxes on accommodation services provided to bystanders and outpatients in their guest accommodation 'Aster Suites'. The department alleged that accommodation services provided at Aster Suites is similar to accommodation at hotels and hence they are taxable. However, the Company has taken the position that accommodation services is part of composite supply of healthcare services wherein bystander accommodation is ancillary or integral to the healthcare services being rendered. However, department has issued the order on 26th Dec 2024 which is not in the favour of Company and raised demand amounting to INR 2.91 Crores along with penalty of 100%. Company has filed the appeal against the said demand on 24th March 2025 stating the facts to the GST Authority and paid 10% pre-deposit amount of demand raised to file the appeal to the Appellate authority. After filing the appeal, no further communication from the department.

Notice for conducting department audit under Section 65 of CGST Act, 2017: Notice for conducting department audit under Section 65 of CGST Act, 2017 for the FY 2018-19 to FY 2022-23 issued. Company has produced the document required for audit purpose.

Requisition of certain information by issuing notice dated 19th November 2024 : Department has conducted enquiry on Stake Sale in M/s Aster DM Healthcare Limited and request for certain set of documents. Company was requested to submit SPA, SHA, Promotional agreement and other document relevant to the stake sale. Company filed response against the same to the Department on dated 26th November 2024 via mail.

ASMT-10 issued with respect to difference in ITC claimed in GSTR 3B and ITC available in GSTR 2A: The notices enquired about the reason for difference in ITC claimed in GSTR 3B and ITC available in GSTR 2A for the period FY 2023-24.

After due consideration of the merits and materiality, the Company elected not to file an appeal. The matter has attained finality.

The Department issued a notice to the Company stating that Company has filed return of income declaring total amount at Nil after set off BFDL amounts to INR 14,54,708. Return was selected for scrutiny and Notice u/s 142(1) dated 13th July 2015 was issued, against which AR Shri R. Ganesh from Rangamani & Co represented from time to time and submitted the required details. The department issued order on 26th Feb 2016 u/s 143(3) and disallowed INR 22,930 for the Kochi Medcity project, INR 25,12,379 of common expenses, and INR 50,55,986 related to exempt income under Rule 8D.

Company has submitted the initial set of documents via portal on 15th June 2025. Company has taken two month of adjournment for submitting the pending details. Further company has submitted the remaining documents on 23rd August 2025. Post submission of details, department has issued audit observation letter for FY 21-22 where they have identified certain discrepancies on 11th Sep 2025. Management has provided the relevant details on 18th September 2025. Post submission of clarification for audit observation, department has dropped the proceeding for FY 21-22 on 26th Sep 2025.

Form GST ADT - 01 notice issued for conducting department audit under Section 65 of CGST Act, 2017 : The department has issued notice to produce certain document for initiation of Department audit like GSTR return working, RCM register etc.

GST Show cause notice and demand order issued for Aster DM Kerela GST registration under section 74(1) of CGST Act, 2017: The department has issued notice to the company requiring the reason to state that why the GST has not been paid on insurance processing fees collected from patient from FY 2019-20 to 2023-24. The company submitted its response on the portal on 29th October 2025. Subsequently, the department issued a demand order dated 24th March 2026, holding the company liable to pay GST on insurance processing fees. A demand of INR 0.36 crore has been raised along with a 100% penalty.

Notice for conducting department audit under Section 65 of CGST Act, 2017: Notice for conducting department audit under Section 65 of CGST Act, 2017 for the FY 2022-23 issued. Company have submitted the required details to the department over the mail.

Considering the immateriality of the amount involved and the facts of the case, the Company, based on careful assessment, decided not to pursue further appellate proceedings. Accordingly, the matter stands concluded.

The department issued order under section 147 r.w.s. 144 and made disallowance of: i) INR 34,00,225 for expenditure related to exempt income under section 14A. ii) INR 10,15,430 for foreign exchange loss on machine import for the Aster Medcity project, which should be capitalized under section 43A. The order was passed u/s 147 r.w.s. 144 confirming the income as per order u/s 154 of INR 26 lakhs

The company received an assessment order on 29th Dec 2016, stating that FTC is not available for dividend received from Affinity Mauritius. However, the company follows the India-Mauritius tax treaty (Article 23), allowing FTC for Mauritian tax paid on dividends if the Indian company holds at least 10% of the Mauritian company’s shares. The company has obtained a legal opinion supporting this view. Department has disallowance the expenditure incurred to INR 1,33,53,573 on account of 14A, 43B of income tax etc. An appeal was filed on 27th Jan 2017, stating that the entire Mauritian tax payable should be eligible for FTC.

The company received an assessment order on 21st Dec 2017, stating that FTC is not available for dividend received from Affinity Mauritius. However, the company follows the India-Mauritius tax treaty (Article 23), allowing FTC for Mauritian tax paid on dividends if the Indian company holds at least 10% of the Mauritian company’s shares. The company has obtained a legal opinion supporting this view. Department has disallowance the expenditure incurred to INR 1,86,53,445 on account of 14A, 43A, mismatch in 26AS etc. An appeal was filed against the CIT(A) on 25th Jan 2018, stating that the entire Mauritian tax payable should be eligible for FTC.

The company received an assessment order on 31st March 2022 disallowing the expenditure such as ESOP expenses, deduction u/s 35AD, Expenditure in relation to exempt income, Foreign exchange fluctuation loss and income in relation to unbilled revenue which has already been taxed earlier result in double taxation on the same income in different assessment years. Company had filed appeal against the said disallowance at CIT(A) on 26th April 2022.