Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
Foreign tax credit claim for doubly taxed foreign sourced salary income was denied due to belated filing of Form No. 67. The Tribunal allowed the assessee's claim, following its coordinate bench rulings granting relief in similar cases. The Departmental Representative failed to distinguish the cited judgments or provide cogent arguments for a contrary view. Consequently, the Tribunal held that the assessee is entitled to foreign tax credit irrespective of the belated Form No. 67 filing, allowing all grounds raised.
Foreign tax credit claim for doubly taxed foreign sourced salary income was denied due to belated filing of Form No. 67. The Tribunal allowed the assessee's claim, following its coordinate bench rulings granting relief in similar cases. The Departmental Representative failed to distinguish the cited judgments or provide cogent arguments for a contrary view. Consequently, the Tribunal held that the assessee is entitled to foreign tax credit irrespective of the belated Form No. 67 filing, allowing all grounds raised.
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