Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Foreign Tax Credit (FTC) u/s 90 r.w. Article 25 India US Treaty (DTAA) - Claim denied as Assessee could not file Form 67 online along with return - The Tribunal accepted the appellant's plea of a reasonable cause for the delay, as evidenced by medical documentation, and condoned the delay, allowing the appeal to proceed. - The Tribunal agreed with the appellant's contention, emphasizing that procedural law should not be construed as mandatory when it obstructs justice. It noted that the DTAA provisions override those of the Income Tax Act if they are more beneficial to the taxpayer.
Foreign Tax Credit (FTC) u/s 90 r.w. Article 25 India US Treaty (DTAA) - Claim denied as Assessee could not file Form 67 online along with return - The Tribunal accepted the appellant's plea of a reasonable cause for the delay, as evidenced by medical documentation, and condoned the delay, allowing the appeal to proceed. - The Tribunal agreed with the appellant's contention, emphasizing that procedural law should not be construed as mandatory when it obstructs justice. It noted that the DTAA provisions override those of the Income Tax Act if they are more beneficial to the taxpayer.
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