Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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The Income Tax Appellate Tribunal (ITAT) held that denial of tax relief u/s 90/90A solely due to procedural delay in filing Form-67 is unjustified. Filing of Form-67 is a procedural formality and cannot be the basis for denying relief to the assessee. The Commissioner of Income Tax (Appeals) [CIT(A)] erred by merely stating disagreement with a binding superior court judgment without assigning any reasons, which is legally unjustifiable. An inferior court differing from a superior court's judgment must discuss and provide reasons for the divergence. The Assessing Officer should not have denied relief u/s 90 merely for the delay in filing Form-67. The assessee's appeal was allowed.
The Income Tax Appellate Tribunal (ITAT) held that denial of tax relief u/s 90/90A solely due to procedural delay in filing Form-67 is unjustified. Filing of Form-67 is a procedural formality and cannot be the basis for denying relief to the assessee. The Commissioner of Income Tax (Appeals) [CIT(A)] erred by merely stating disagreement with a binding superior court judgment without assigning any reasons, which is legally unjustifiable. An inferior court differing from a superior court's judgment must discuss and provide reasons for the divergence. The Assessing Officer should not have denied relief u/s 90 merely for the delay in filing Form-67. The assessee's appeal was allowed.
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