Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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