Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
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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