PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
Assessee's claim for foreign tax credit u/s 90 allowed despite delay in filing Form No. 67 after due date of filing return u/s 139(1). Delay in filing Form 67 cannot deny vested right to claim foreign tax credit under DTAA. ITAT relied on Chiragkumar Nandalal Makadia ruling that late filing of Form 67 cannot be reason for denying foreign tax credit benefit. Rule 128 mandating Form 67 filing before return is procedural; non-compliance should not result in denial of foreign tax credit. Assessee's appeal allowed.
Assessee's claim for foreign tax credit u/s 90 allowed despite delay in filing Form No. 67 after due date of filing return u/s 139(1). Delay in filing Form 67 cannot deny vested right to claim foreign tax credit under DTAA. ITAT relied on Chiragkumar Nandalal Makadia ruling that late filing of Form 67 cannot be reason for denying foreign tax credit benefit. Rule 128 mandating Form 67 filing before return is procedural; non-compliance should not result in denial of foreign tax credit. Assessee's appeal allowed.
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