Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
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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