Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
Scientific research association approval requires continuing SIRO status, annual donation reporting, and donor certificates for the approved foundatio...
Scientific research institution approval is conditional on SIRO recognition, annual donation reporting, donor certification, and prescribed compliance...
The Tribunal held that Rule 128(9) does not provide for disallowance of Foreign Tax Credit (FTC) in case of delay in filing Form No. 67. Filing of Form No. 67 is a directory requirement, and the Double Taxation Avoidance Agreement (DTAA) overrides the provisions of the Act and Rules. The issue was not debatable, and there was only one possible view. In such circumstances, proceedings u/s 154 of the Act can be resorted to, even if it involves a long-drawn process of reasoning. The Assessing Officer was directed to give credit for foreign tax as per Form 67 filed by the assessee prior to filing the appeal before the Commissioner of Income Tax (Appeals), after due verification.
The Tribunal held that Rule 128(9) does not provide for disallowance of Foreign Tax Credit (FTC) in case of delay in filing Form No. 67. Filing of Form No. 67 is a directory requirement, and the Double Taxation Avoidance Agreement (DTAA) overrides the provisions of the Act and Rules. The issue was not debatable, and there was only one possible view. In such circumstances, proceedings u/s 154 of the Act can be resorted to, even if it involves a long-drawn process of reasoning. The Assessing Officer was directed to give credit for foreign tax as per Form 67 filed by the assessee prior to filing the appeal before the Commissioner of Income Tax (Appeals), after due verification.
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TaxTMI 
TaxTMI 
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