Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
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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