Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Transitional credit - Unutilized amount of Advanced VAT paid - The court found that if the amount of advance tax paid under the VAT regime remained unutilized, it should be allowed to transition to the GST regime u/s 140 of the TNGST Act, 2017. This section clearly allows the transitioning of unutilized VAT and Entry Tax. Citing decisions from the Telangana and Madras High Courts, the judge supported a purposive interpretation of Section 140, which should extend to advance tax paid and unutilized under the previous tax regime.
Transitional credit - Unutilized amount of Advanced VAT paid - The court found that if the amount of advance tax paid under the VAT regime remained unutilized, it should be allowed to transition to the GST regime u/s 140 of the TNGST Act, 2017. This section clearly allows the transitioning of unutilized VAT and Entry Tax. Citing decisions from the Telangana and Madras High Courts, the judge supported a purposive interpretation of Section 140, which should extend to advance tax paid and unutilized under the previous tax regime.
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