Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
The High Court, following the judgment in G.M. Knitting Industries (P.) Ltd., held that filing a foreign tax credit claim u/r 128 is directory and not mandatory. The petitioner, an Indian resident working in the UK, filed an Indian tax return claiming foreign tax credit u/s 90 but uploaded Form 67 with delay due to COVID-related difficulties in obtaining foreign documents. The court condoned the delay, noting Sections 90, 90A, and 91 aim to avoid double taxation. Despite the delayed Form 67 filing, the impugned order was set aside, allowing the foreign tax credit claim under Article 24 of the India-UK tax treaty.
The High Court, following the judgment in G.M. Knitting Industries (P.) Ltd., held that filing a foreign tax credit claim u/r 128 is directory and not mandatory. The petitioner, an Indian resident working in the UK, filed an Indian tax return claiming foreign tax credit u/s 90 but uploaded Form 67 with delay due to COVID-related difficulties in obtaining foreign documents. The court condoned the delay, noting Sections 90, 90A, and 91 aim to avoid double taxation. Despite the delayed Form 67 filing, the impugned order was set aside, allowing the foreign tax credit claim under Article 24 of the India-UK tax treaty.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
