Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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Foreign tax credit under sections 90/90A was remitted for fresh verification because the assessee's USA tax return for Calendar Year 2023 was now available along with the earlier 2022 return. The Tribunal noted that the appellate authority had already directed verification and proportionate relief for the 2022 period, and that the complete foreign income and tax-paid details for the full financial year 2022-23 were therefore capable of examination. The matter was restored to the Assessing Officer for de novo adjudication after verifying the USA returns for 2022 and 2023 and granting relief as per law.
Foreign tax credit under sections 90/90A was remitted for fresh verification because the assessee's USA tax return for Calendar Year 2023 was now available along with the earlier 2022 return. The Tribunal noted that the appellate authority had already directed verification and proportionate relief for the 2022 period, and that the complete foreign income and tax-paid details for the full financial year 2022-23 were therefore capable of examination. The matter was restored to the Assessing Officer for de novo adjudication after verifying the USA returns for 2022 and 2023 and granting relief as per law.
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