Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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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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