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...
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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