Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
Delayed filing of Form No. 67 did not, by itself, justify denial of foreign tax credit; the Tribunal treated the Rule 128 timeline as a directory procedural requirement and directed allowance of the claim subject to verification. The assessee's alternative plea that ESOP perquisites were not taxable in India because of his residential status was not examined on the additional passport and travel material; that issue was remitted for fresh adjudication after factual verification.
Delayed filing of Form No. 67 did not, by itself, justify denial of foreign tax credit; the Tribunal treated the Rule 128 timeline as a directory procedural requirement and directed allowance of the claim subject to verification. The assessee's alternative plea that ESOP perquisites were not taxable in India because of his residential status was not examined on the additional passport and travel material; that issue was remitted for fresh adjudication after factual verification.
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