Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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