Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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The Appellate Tribunal addressed the disallowance of benefit u/s 90/90A for foreign tax paid in Bhutan due to Form No. 67 not filed within time frame. Relying on legal precedents, including Duraiswamy Kumaraswamy, it held that failure to file Form No. 67 timely does not bar claiming foreign tax credit. The assessee's claim was allowed as Form No. 67 was filed with the return u/s 139(4). The Assessing Officer was directed to grant foreign tax credit as per law and India-Bhutan DTAA u/s 90. The appeal of the assessee was upheld.
The Appellate Tribunal addressed the disallowance of benefit u/s 90/90A for foreign tax paid in Bhutan due to Form No. 67 not filed within time frame. Relying on legal precedents, including Duraiswamy Kumaraswamy, it held that failure to file Form No. 67 timely does not bar claiming foreign tax credit. The assessee's claim was allowed as Form No. 67 was filed with the return u/s 139(4). The Assessing Officer was directed to grant foreign tax credit as per law and India-Bhutan DTAA u/s 90. The appeal of the assessee was upheld.
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