Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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