Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Foreign Tax Credit u/s. 90 - Assessee did not file Form 67 at the time of filing of her return of income - Referring to established case law, the Tribunal affirmed that Rule 128 of the Income Tax Rules, which prescribes Form 67, is directory and not mandatory. Therefore, the delay in filing this form should not be a ground for rejecting the Foreign Tax Credit claim. Considering the submission and the legal standpoint, the Tribunal concluded that the rejection of the Foreign Tax Credit claim solely based on the delay in filing Form 67 was not justifiable.
Foreign Tax Credit u/s. 90 - Assessee did not file Form 67 at the time of filing of her return of income - Referring to established case law, the Tribunal affirmed that Rule 128 of the Income Tax Rules, which prescribes Form 67, is directory and not mandatory. Therefore, the delay in filing this form should not be a ground for rejecting the Foreign Tax Credit claim. Considering the submission and the legal standpoint, the Tribunal concluded that the rejection of the Foreign Tax Credit claim solely based on the delay in filing Form 67 was not justifiable.
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