Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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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