Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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