Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
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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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