Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Disallowance of foreign tax credits - failure to the requisite documents as specified u/s 128(8) - Considering the fact that the assessee is stated to be in possession of documentary evidence, as required under rule 128(8) and (9), we direct the assessee to furnish them before AO for examination. AO is directed to verify the documentary evidences filed or to be filed by the assessee and allow foreign tax credit in accordance with the extant rules read with section 90 of the Act. - AT
Disallowance of foreign tax credits - failure to the requisite documents as specified u/s 128(8) - Considering the fact that the assessee is stated to be in possession of documentary evidence, as required under rule 128(8) and (9), we direct the assessee to furnish them before AO for examination. AO is directed to verify the documentary evidences filed or to be filed by the assessee and allow foreign tax credit in accordance with the extant rules read with section 90 of the Act. - AT
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