Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
The Appellate Tribunal (ITAT) considered the denial of Foreign Tax Credit (FTC) u/s late filing of Form 67. The assessee argued that Form 67 filing is procedural, not mandatory. ITAT held that Form 67 filing is directory, not mandatory, and non-compliance does not affect substantive rights. Orders below were set aside, directing the Assessing Officer to verify FTC claim upon accepting Form 67. The appeal of the assessee was allowed.
The Appellate Tribunal (ITAT) considered the denial of Foreign Tax Credit (FTC) u/s late filing of Form 67. The assessee argued that Form 67 filing is procedural, not mandatory. ITAT held that Form 67 filing is directory, not mandatory, and non-compliance does not affect substantive rights. Orders below were set aside, directing the Assessing Officer to verify FTC claim upon accepting Form 67. The appeal of the assessee was allowed.
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