CIT v. Manipal Health Systems (P.) Ltd.

375 ITR 509High Court2015#5272 most cited

What is CIT v. Manipal Health Systems (P.) Ltd. authority for?

The distinction between a 'contract for service' and a 'contract of service' hinges on multi-factor tests, including the independence, control, and intention tests, and is ultimately determined by the contract's provisions.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v. Manipal Health Systems · contract for service · contract of service · employer-employee relationship · independence test · control test · intention test · section 194J · section 192 · section 201(1A)

Sections most often in play

Section 192Section 194JSection 201(1A)

Issues it is cited on

section 194jsection 192section 201(1a)assessee in defaultreasoned ordersection 194section 19transferpersoncompanynfacbusiness

Judgments citing CIT v. Manipal Health Systems (P.) Ltd.

M/S Hosmat Hospital Pvt. Ltd., Bangalore vs. ACIT, Bangalore

In the result, the appeals filed by the revenue are also dismissed

ITA 575/BANG/2014[2012-13]Status: DisposedITAT Bangalore11 Aug 2016AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri S.Annamalai, AdvocateFor Respondent: Shri Sunil Kumar Agarwal, JCIT(DR)
Section 133ASection 192Section 194JSection 201Section 201(1)

…relationship of employer and employee, it is to be examined whether the contract entered into between the parties is ‘contract for service’ or ‘contract of service’. The Hon'ble jurisdictional High Court in the case of CIT vs. Manipal Health System (P) Ltd. (375 ITR 509) vide para.13 of the judgment held as follows: “13. To decide the relationship of employer and employee we have to examine whether the contract entered into between the parties is a ‘contract for service’ or a ‘contract of service’. There are multi-factor tests to decide this question. Independence test, control test, intention test are some of…

M/S Hosmat Hospital Pvt. Ltd., Bangalore vs. ACIT, Bangalore

In the result, the appeals filed by the revenue are also dismissed

ITA 572/BANG/2014[2012-13]Status: DisposedITAT Bangalore11 Aug 2016AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri S.Annamalai, AdvocateFor Respondent: Shri Sunil Kumar Agarwal, JCIT(DR)
Section 133ASection 192Section 194JSection 201Section 201(1)

…relationship of employer and employee, it is to be examined whether the contract entered into between the parties is ‘contract for service’ or ‘contract of service’. The Hon'ble jurisdictional High Court in the case of CIT vs. Manipal Health System (P) Ltd. (375 ITR 509) vide para.13 of the judgment held as follows: “13. To decide the relationship of employer and employee we have to examine whether the contract entered into between the parties is a ‘contract for service’ or a ‘contract of service’. There are multi-factor tests to decide this question. Independence test, control test, intention test are some of…