Timely pronouncement of reserved judgments requires defined timelines, transparency measures, and remedial pathways to protect liberty and effective j...
Settlement-price depression requires proof of manipulation, not merely short exposure, late selling, or below-market orders, preserving disclosure pen...
Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Disallowance of Foreign Tax Credit (FTC) - delay in filing Form 67 - Rule 128(9) of the Rules has to be read down in conformity thereof. Rule 128(9) of the Rules cannot be read in isolation. Rules must be read in the context of the Act and the DTAA impacting the rights, liabilities and disabilities of the parties. - AT
Disallowance of Foreign Tax Credit (FTC) - delay in filing Form 67 - Rule 128(9) of the Rules has to be read down in conformity thereof. Rule 128(9) of the Rules cannot be read in isolation. Rules must be read in the context of the Act and the DTAA impacting the rights, liabilities and disabilities of the parties. - AT
Note: It is a system-generated summary and is for quick reference only.