Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
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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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