Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
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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