Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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