Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Foreign tax credit on foreign dividend income cannot be denied solely because the prescribed form was furnished after the original-return due date but before the revised return and the end of the assessment year. Where the governing statute imposes no filing deadline and the procedural rule neither links delay to denial nor lists delayed filing as a disqualifying circumstance, the filing requirement operates as directory. Rectification is available where processing annexures recognise foreign tax credit as available but the computation simultaneously records it as nil, since that internal inconsistency is a mistake apparent from the record. The credit is to be allowed, while the processing adjustment remains open to challenge.
Foreign tax credit on foreign dividend income cannot be denied solely because the prescribed form was furnished after the original-return due date but before the revised return and the end of the assessment year. Where the governing statute imposes no filing deadline and the procedural rule neither links delay to denial nor lists delayed filing as a disqualifying circumstance, the filing requirement operates as directory. Rectification is available where processing annexures recognise foreign tax credit as available but the computation simultaneously records it as nil, since that internal inconsistency is a mistake apparent from the record. The credit is to be allowed, while the processing adjustment remains open to challenge.
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TaxTMI 
TaxTMI 
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