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Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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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