Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
Addresses allowability of Foreign Tax Credit where Form 67 was filed late under Rule 128(9); holds the rule is directory and procedural delay alone cannot defeat relief under the DTAA and sections 90/91 when foreign income and supporting evidence were placed on record before completion of assessment. Directs assessing officer to verify tax payment proof already submitted and decide the FTC claim in accordance with law; remits matter for verification and potential grant of credit where due.
Addresses allowability of Foreign Tax Credit where Form 67 was filed late under Rule 128(9); holds the rule is directory and procedural delay alone cannot defeat relief under the DTAA and sections 90/91 when foreign income and supporting evidence were placed on record before completion of assessment. Directs assessing officer to verify tax payment proof already submitted and decide the FTC claim in accordance with law; remits matter for verification and potential grant of credit where due.
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