Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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