Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
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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