Statutory transfer formalities invalidated alleged share and property transfers, while retrospective record manipulation constituted oppression and mi...
Provisional attachment of laundered funds and equivalent-value property sustained, with statutory protection limited to pension, gratuity and providen...
Insolvency moratorium does not shield company officers from cheque dishonour prosecution for liability arising before corporate insolvency proceedings...
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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