Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
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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