Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
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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