Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
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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