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...
Foreign tax credit should not be denied where Form No. 67 was available on or before the return-filing due date and the claim was supported by the return. Submission of the form, foreign tax deduction certificate, and material on the corresponding foreign income requires verification, since tax cannot be collected without authority of law; the credit claim was remanded for verification and consequential grant if allowable. Delay in electronically filing an appeal in Form No. 35 may be condoned where lack of awareness of the electronic process and available appellate remedy constitutes sufficient cause, particularly when the appeal is filed promptly after professional advice.
Foreign tax credit should not be denied where Form No. 67 was available on or before the return-filing due date and the claim was supported by the return. Submission of the form, foreign tax deduction certificate, and material on the corresponding foreign income requires verification, since tax cannot be collected without authority of law; the credit claim was remanded for verification and consequential grant if allowable. Delay in electronically filing an appeal in Form No. 35 may be condoned where lack of awareness of the electronic process and available appellate remedy constitutes sufficient cause, particularly when the appeal is filed promptly after professional advice.
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