Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Customs-controlled container movement now extends to DP World facilities, subject to segregation, inspections, reconciliation, and EXIM cargo priority...
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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