Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
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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