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...
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The High Court held that for a works contract involving construction of a barrage across two states, Telangana and Maharashtra, the place of supply would be determined proportionately based on the value of services rendered in each state as per Section 12(3) of the IGST Act. Consequently, the supply would qualify as an intra-state supply u/s 8 of the IGST Act in proportion to the work executed in the respective states by the contractors registered there. The tax liability must be discharged individually in each state commensurate with the work executed therein. The petitioner's refund claim for TDS was rejected due to lack of evidence regarding discharge of tax liability in Maharashtra. However, the High Court allowed the petitioner to approach the adjudicating authority with relevant documents proving tax payment in Maharashtra for reconsideration of the refund claim after due opportunity to both parties.
The High Court held that for a works contract involving construction of a barrage across two states, Telangana and Maharashtra, the place of supply would be determined proportionately based on the value of services rendered in each state as per Section 12(3) of the IGST Act. Consequently, the supply would qualify as an intra-state supply u/s 8 of the IGST Act in proportion to the work executed in the respective states by the contractors registered there. The tax liability must be discharged individually in each state commensurate with the work executed therein. The petitioner's refund claim for TDS was rejected due to lack of evidence regarding discharge of tax liability in Maharashtra. However, the High Court allowed the petitioner to approach the adjudicating authority with relevant documents proving tax payment in Maharashtra for reconsideration of the refund claim after due opportunity to both parties.
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