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...
Entitlement to foreign tax credit - The Tribunal concludes that the filing of Form 67 is a procedural requirement and should be construed as directory rather than mandatory. It emphasizes that the violation of procedural norms does not extinguish the substantive right of claiming the foreign tax credit. - The Tribunal directs the Assessing Officer to grant the foreign tax credit to the assessee, based on its interpretation of the relevant provisions and judicial precedents.
Entitlement to foreign tax credit - The Tribunal concludes that the filing of Form 67 is a procedural requirement and should be construed as directory rather than mandatory. It emphasizes that the violation of procedural norms does not extinguish the substantive right of claiming the foreign tax credit. - The Tribunal directs the Assessing Officer to grant the foreign tax credit to the assessee, based on its interpretation of the relevant provisions and judicial precedents.
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