Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computationa...
Denial of Foreign tax credit - If the finding of lower authority regarding place of effective management is presumed to be correct, in that case, no tax could be charged as the transaction took place off shores and income was generated in USA - Benefit of FTC allowed - AT
Denial of Foreign tax credit - If the finding of lower authority regarding place of effective management is presumed to be correct, in that case, no tax could be charged as the transaction took place off shores and income was generated in USA - Benefit of FTC allowed - AT
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