Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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