Unlawful outward remittances via Hawala using proforma invoices and electronic records proved; documents admitted, directors penalised, penalties redu...
Attachment of equivalent-value properties as proceeds of crime upheld; preventive attachment order and confirmation sustained; no independent ED reinv...
Broker trading-system "technical glitch" redefinition and narrowed incident-reporting regime for large IBT/STWT brokers requiring 2-hr notice and 14-w...
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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