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Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
The assessee, a salaried employee working for Tessolve Semiconductor Pvt. Ltd. and Tessolve Inc., earned income from salary, house property, capital gains, dividend, and interest. The assessee claimed foreign tax credit, which was denied by the CPC due to the late filing of Form 67 along with the return of income u/s 139. The Tribunal, relying on a previous Bangalore Bench decision, held that Rule 128(9) does not provide for disallowance of FTC in case of delay in filing Form 67. Filing Form 67 is a directory requirement, and the DTAA overrides the provisions of the Act. The Tribunal directed the Assessing Officer to allow Foreign Tax Credit after due verification of Form 67, allowing the assessee's appeal for statistical purposes.
The assessee, a salaried employee working for Tessolve Semiconductor Pvt. Ltd. and Tessolve Inc., earned income from salary, house property, capital gains, dividend, and interest. The assessee claimed foreign tax credit, which was denied by the CPC due to the late filing of Form 67 along with the return of income u/s 139. The Tribunal, relying on a previous Bangalore Bench decision, held that Rule 128(9) does not provide for disallowance of FTC in case of delay in filing Form 67. Filing Form 67 is a directory requirement, and the DTAA overrides the provisions of the Act. The Tribunal directed the Assessing Officer to allow Foreign Tax Credit after due verification of Form 67, allowing the assessee's appeal for statistical purposes.
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