Ministerial policy priorities for India's trade, investment and technology agenda emphasise artificial intelligence, cybersecurity, technology adoption, manufacturing investment and lifelong skill development. Investment competitiveness is linked to political stability, resilient supply chains, and fair and transparent trading practices. The first tranche of a bilateral trade agreement with the United States has been finalised, while final contours and legal drafting continue before operationalisation.

Legacy tax arrears and inadmissible input tax credit arising under the pre-GST regime are recoverable as arrears of tax under the Tamil Nadu GST framework where unrecovered under the existing law. Arrears relating to legacy taxes, wrongly availed input tax credit, and improperly carried-forward transitional credit are treated as State tax liabilities and may be paid through the electronic credit ledger or electronic cash ledger. Interest, penalty and late fee must be paid only through the electronic cash ledger, with all such liabilities recorded in Part II of the Electronic Liability Register.

Punjab Goods and Services Tax framework extends the period specified in rule 137 from four years to five years, effective 30 November 2021. FORM GST DRC-03 now expressly covers tax intimation through FORM GST DRC-01A and payment contexts including scrutiny, audit, inspection, investigation and specified return mismatches. Its revised payment table records tax period, place of supply, tax components, total amount, cash or credit ledger utilisation, and debit-entry details.

Swachh Bharat Cess and Krishi Kalyan Cess paid on eligible taxable services used for exporting goods are refundable under Notification No. 41/2012-ST. The Finance Act, 2015 and Finance Act, 2016 treat the respective cesses as service tax for refund purposes and apply service-tax refund provisions to them. A harmonious reading of those provisions with the notification supports refund eligibility for export-related services, consistent with the principle that taxes should not be exported.

Exporters may submit a Letter of Undertaking electronically in FORM GST RFD-11 through the common portal. The LUT is deemed accepted when an online acknowledgement bearing an Application Reference Number is generated, and no physical documents are required for its acceptance. Acceptance remains conditional on prescribed eligibility to furnish an LUT instead of a bond; an ineligible exporter's LUT may be rejected ab initio.

GSTN, Central and State authorities are to appoint and publicise nodal officers. Taxpayers must apply to field or nodal officers, identify the demonstrable portal glitch, and furnish evidence of their bona fide compliance attempt. Nodal officers collate applications for GSTN verification against electronic records. GSTN identifies issues affecting a large taxpayer class, submits proposed solutions to the IT Grievance Redressal Committee, and the committee may approve modified solutions and direct GSTN and field formations to implement them.

Completed assessments under Section 153A permit additions only where incriminating material is found during the search. Statements or information obtained through post-search collateral enquiries cannot replace that jurisdictional requirement, particularly where a loan was already disclosed in the books and balance sheet. An unsecured loan is not liable to addition as unexplained cash credit where confirmation, PAN, tax return records, audited financial statements and bank evidence establish the lender's identity, creditworthiness and the transaction's genuineness. Banking-channel repayment and interest payments with tax deduction further support the disclosed loan.

Punjab GST amendments extend the specified rule 117 timelines to 31 March 2020 and 30 April 2020, update SEZ registration particulars in FORM REG-01, and revise return-defaulter notices in FORM GSTR-3A. They also replace FORM INV-01 with an e-invoice schema prescribing Invoice Reference Number registration, structured supplier, buyer, payment, delivery, item, tax, total, transport and digital-signature data, together with cardinality, format and mandatory or optional field specifications.

GST treatment of joint venture cash calls depends on whether the payment is a mere contribution of money or consideration for a supply. Contributions pooled by an operating member to acquire machinery for joint venture use are capital contributions and transactions in money, without a supply for consideration. Where the operating member uses its own machinery to perform activities for the joint venture and recovers costs from other members according to their participating interests, it supplies taxable services. The joint venture agreement and related arrangements determine the taxability of each cash call.

Intervener standing in writ proceedings does not extend to appellate standing where the intervener was not a party to the writ petition. Participation before the Single Judge solely as an intervener confers no appellate right superior to that of parties to the writ action. The intervener may nevertheless make submissions before the appropriate court on the underlying issue.

State and Union tax authorities cannot simultaneously initiate action against the same assessee for identical tax periods. Parallel proceedings by both authorities for the relevant periods are impermissible, and only one authority may exercise jurisdiction for those periods. This prevents overlapping enforcement action concerning the same taxable person and period.

GST classification of bus body building as a composite supply depends on the principal supply identified from the facts. Tyre retreading is ordinarily a service because retreading imparts the essential character and rubber is ancillary; value is only a guiding factor. Retreaded tyres supplied where the old tyres belong to the supplier are goods. Priority Sector Lending Certificates and Renewable Energy Certificates are goods classifiable under heading 4907, while duty credit scrips receive nil GST. Electricity transmission or distribution by a utility is exempt, but specified ancillary consumer charges and government loan guarantees for consideration are taxable.

Input tax credit conditions distinguish a bar on credit being taken from a restriction on its utilisation. Where credit is not taken, it cannot be entered into the Electronic Credit Ledger for goods or services used in the relevant supply. Where credit is not utilised, it may be availed and pooled but cannot be set off against tax on the specified railway service. Such credit may remain available for other eligible taxable outward supplies.

Rule 8 governing Punjab GST registration is amended, generally with effect from 11 September 2024, to replace the Aadhaar-authentication process for applicants other than persons notified under section 25(6D). Where common-portal data analysis and risk parameters identify an Aadhaar-authenticating applicant, completion additionally requires biometric-based Aadhaar authentication, a photograph, and verification of original uploaded documents at a facilitation centre notified for this purpose.

Input tax credit on foreign-exchange conversion, card and account-operation charges may be claimed where these are business overheads. Banking companies and financial institutions may issue a consolidated monthly tax invoice or another qualifying document. A bank statement may support the credit claim where it contains the prescribed invoice particulars. Where GSTR-2B entries do not reconcile with bank deductions, a consolidated invoice may assist reconciliation.

Transfer-pricing comparability under the transactional net margin method requires a separate functions, assets and risks analysis for every proposed comparable. Retaining Infosys BPO Ltd., where its suitability was not challenged, does not establish the functional comparability of other high-end ITES entities. Low-end ITES/BPO providers should not be benchmarked against Eclerx Services Ltd., whose analytics and knowledge-process outsourcing functions materially differ. ICRA Techno Analytics Ltd.'s segment, involving business analytics, operational solutions and internally developed customised software, is likewise functionally dissimilar. The appropriate comparable set therefore excludes dissimilar KPO and business-analytics entities when determining the arm's-length price.

Appeals against orders imposing penalty without a tax demand require payment of ten per cent of the penalty at the first appellate stage and a further prescribed payment for appeal to the Appellate Tribunal. A track-and-trace mechanism may be prescribed for notified goods and persons dealing in them. Covered persons may be required to affix unique identification markings, furnish information and machinery details, maintain records, and pay prescribed system-related amounts. Contravention attracts an additional penalty equal to the higher of the specified fixed amount or ten per cent of the tax payable on the goods.

Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to the Revenue; Explanation 2 does not displace these twin conditions. Where scrutiny examined JDA receipts, capital-gains treatment, records and explanations, revision cannot substitute another plausible view or commence a fishing inquiry. A landowner's revenue share under a Joint Development Agreement is long-term capital gain where the land remains a capital asset and the developer alone bears construction, approvals, marketing, funding and project risks. Deferred receipt of agreed consideration does not, by itself, create an adventure in the nature of trade or business income.

Provisional attachment of a bank account under Section 83(2) ceases to operate once the statutory one-year period from the attachment order expires. Expiry of that period causes the attachment to lapse, requiring the bank account to be de-frozen. The respondents accepted that the attachment had expired under the statutory time limit and no continued restraint could be maintained.

A supplier's output tax liability cannot be reduced through a credit note where a registered recipient has not reversed attributable input tax credit, or where the tax incidence has been passed on to another person. Appeals against penalty-only orders require prescribed pre-deposits. Specified goods may be subject to a unique identification marking regime requiring affixation of markings, information reporting, record maintenance and machinery disclosures, with additional penalties for contravention.