Coercive recovery during GST searches is restrained pending scrutiny, preserving normal business operations and requiring adherence to investigation g...
COVID-19 limitation exclusion and destination-specific e-way bills govern revisional timelines and penalties for undocumented third-party plywood deli...
Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
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Foreign withholding tax eligible for double-taxation relief under sections 90 or 91 cannot be deducted as business expenditure merely because nil Indian tax liability prevents use of the credit. Explanation 1 to section 40(a)(ii) applies based on eligibility for relief, not actual allowance or utilisation; the claimed deduction was therefore rejected. An additional legal claim for that deduction, raised before the first appellate authority, required examination on merits where the return and Form 67 contained the relevant material. Rule 46A did not justify threshold rejection, although the claim ultimately failed.
Foreign withholding tax eligible for double-taxation relief under sections 90 or 91 cannot be deducted as business expenditure merely because nil Indian tax liability prevents use of the credit. Explanation 1 to section 40(a)(ii) applies based on eligibility for relief, not actual allowance or utilisation; the claimed deduction was therefore rejected. An additional legal claim for that deduction, raised before the first appellate authority, required examination on merits where the return and Form 67 contained the relevant material. Rule 46A did not justify threshold rejection, although the claim ultimately failed.
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