Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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