Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Belated filing of Form No. 67 for foreign tax credit was treated as a procedural lapse, not a mandatory bar to the claim. Since the form had been filed with the revised return, the credit could not be refused solely on the ground of delay, and the Assessing Officer was required to verify the claim and allow it in accordance with law. The appeal was allowed for statistical purposes with that direction, following the view that Form No. 67 is a directory requirement.
Belated filing of Form No. 67 for foreign tax credit was treated as a procedural lapse, not a mandatory bar to the claim. Since the form had been filed with the revised return, the credit could not be refused solely on the ground of delay, and the Assessing Officer was required to verify the claim and allow it in accordance with law. The appeal was allowed for statistical purposes with that direction, following the view that Form No. 67 is a directory requirement.
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