Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The Appellate Tribunal considered the denial of Foreign Tax Credit (FTC) due to late filing of Form 67. The return of income for AY 2021-22 was filed on 13.10.2021, with Form 67 submitted on 25.01.2022 and a rectified return on 04.09.2022. The Tribunal held that Form 67 filing is procedural, not mandatory, and non-compliance does not affect the substantive right to claim. Therefore, the grounds raised by the appellant were allowed.
The Appellate Tribunal considered the denial of Foreign Tax Credit (FTC) due to late filing of Form 67. The return of income for AY 2021-22 was filed on 13.10.2021, with Form 67 submitted on 25.01.2022 and a rectified return on 04.09.2022. The Tribunal held that Form 67 filing is procedural, not mandatory, and non-compliance does not affect the substantive right to claim. Therefore, the grounds raised by the appellant were allowed.
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TaxTMI 
TaxTMI 
of 4918 
