International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Foreign tax credit could not be denied merely because Form No. 67 was filed after the return due date, as the ITAT treated the filing requirement as directory rather than mandatory. Where the form's contents and the underlying foreign tax credit claim were otherwise not defective, delay in filing alone did not justify rejection of the substantive benefit. The order sustaining denial was set aside and the Assessing Officer was directed to examine the facts and allow the claim in accordance with Form No. 67.
Foreign tax credit could not be denied merely because Form No. 67 was filed after the return due date, as the ITAT treated the filing requirement as directory rather than mandatory. Where the form's contents and the underlying foreign tax credit claim were otherwise not defective, delay in filing alone did not justify rejection of the substantive benefit. The order sustaining denial was set aside and the Assessing Officer was directed to examine the facts and allow the claim in accordance with Form No. 67.
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