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...
Foreign Tax Credit u/s. 90 - denial of tax credit paid in the source country - Form No.67 was not filed before the due date of filing of return of income - While the Tribunal did not directly address the issue of late filing, it emphasized the need for the AO to verify the filing of Form 67 and grant relief accordingly, suggesting a resolution for the delay issue. The Tribunal recognized the discrepancy between the AO's assertion of rejecting the application under Section 154 and the actual allowance of the claim in the order. It directed the AO to rectify this and grant relief if the claim was indeed accepted but not allowed in the final computation.
Foreign Tax Credit u/s. 90 - denial of tax credit paid in the source country - Form No.67 was not filed before the due date of filing of return of income - While the Tribunal did not directly address the issue of late filing, it emphasized the need for the AO to verify the filing of Form 67 and grant relief accordingly, suggesting a resolution for the delay issue. The Tribunal recognized the discrepancy between the AO's assertion of rejecting the application under Section 154 and the actual allowance of the claim in the order. It directed the AO to rectify this and grant relief if the claim was indeed accepted but not allowed in the final computation.
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