Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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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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