Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Transitional credit - TDS was transitioned under Section 140 of the TNGST Act, 2017, along with the “purchase tax” - The High court held that there is no scope for transitioning TDS credit under Section 140 of the TNGST Act, 2017, as it applies only to ITC. However, it noted that if TDS had remained unutilized for discharging tax liability under the TNVAT Act, there should be a fresh adjustment of the amount from VAT-TDS towards the petitioner's tax liability, and any remaining ITC should be transitioned under Section 140 of the TNGST Act, 2017, or refunded.
Transitional credit - TDS was transitioned under Section 140 of the TNGST Act, 2017, along with the “purchase tax” - The High court held that there is no scope for transitioning TDS credit under Section 140 of the TNGST Act, 2017, as it applies only to ITC. However, it noted that if TDS had remained unutilized for discharging tax liability under the TNVAT Act, there should be a fresh adjustment of the amount from VAT-TDS towards the petitioner's tax liability, and any remaining ITC should be transitioned under Section 140 of the TNGST Act, 2017, or refunded.
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