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 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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