Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
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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