Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Denial of claim of Foreign Tax Credit (FTC) - Delay in filing of ITR - Rule 128 is only a procedural provision and not a mandatory provision and cannot override the provisions of the Act or the DTAA - Delay in filing the return and Form No.67 (i.e., beyond period under section 139(1) of the Act) is not fatal to the claim of FTC - AT
Denial of claim of Foreign Tax Credit (FTC) - Delay in filing of ITR - Rule 128 is only a procedural provision and not a mandatory provision and cannot override the provisions of the Act or the DTAA - Delay in filing the return and Form No.67 (i.e., beyond period under section 139(1) of the Act) is not fatal to the claim of FTC - AT
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