Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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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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