Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Denial of Foreign Tax Credit (FTC) claimed u/s. 90 - there was delay in furnishing Form 67 - The Tribunal referred to a similar case where Form 67 was not filed before the processing of the return under section 143(1) of the Act but was filed subsequently. In that case, the Tribunal directed the Assessing Officer (AO) to give credit for FTC after due verification of Form 67. - The Tribunal concluded that the denial of FTC for the delay in filing Form 67 was not justified. Therefore, it directed the AO to give credit for FTC after due verification of Form 67.
Denial of Foreign Tax Credit (FTC) claimed u/s. 90 - there was delay in furnishing Form 67 - The Tribunal referred to a similar case where Form 67 was not filed before the processing of the return under section 143(1) of the Act but was filed subsequently. In that case, the Tribunal directed the Assessing Officer (AO) to give credit for FTC after due verification of Form 67. - The Tribunal concluded that the denial of FTC for the delay in filing Form 67 was not justified. Therefore, it directed the AO to give credit for FTC after due verification of Form 67.
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