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...
Foreign Tax Credit u/s 90/90A - - The Tribunal found that while the DTAA does not prescribe a filing requirement for FTC, the Income Tax Rules (Rule 128) do mandate the filing of Form No. 67 within a specified time limit. It emphasized that the purpose of this requirement is to verify the eligibility, genuineness, and correctness of the FTC claim. - The ITAT concluded that the filing of the claim form along with certificates and statements is mandatory concerning the essence of the FTC claim but directory regarding the time limit. It held that belated compliance does not warrant rejection or denial of the claim.
Foreign Tax Credit u/s 90/90A - - The Tribunal found that while the DTAA does not prescribe a filing requirement for FTC, the Income Tax Rules (Rule 128) do mandate the filing of Form No. 67 within a specified time limit. It emphasized that the purpose of this requirement is to verify the eligibility, genuineness, and correctness of the FTC claim. - The ITAT concluded that the filing of the claim form along with certificates and statements is mandatory concerning the essence of the FTC claim but directory regarding the time limit. It held that belated compliance does not warrant rejection or denial of the claim.
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