https://www.taxtmi.com/caselaws?id=762492 The Appellate Tribunal upheld the denial of the Foreign Tax Credit (FTC) due to the late filing of Form No. 67, affirming its mandatory nature under Rule 128. The Tribunal emphasized the necessity of filing the form within the prescribed timeframe for verification purposes. Regarding the rectification order demanding additional tax payment, the Tribunal noted its issuance without a Document Identification Number (DIN) and directed a comprehensive review alongside the pending appeal against the ex-parte assessment order. The Tribunal did not specifically rule on the applicability of Double Taxation Avoidance Agreement (DTAA) provisions, focusing instead on procedural compliance. en-us Fri, 29 Nov 2024 00:00:00 +0530 Mon, 02 Dec 2024 08:56:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762492 The Appellate Tribunal upheld the denial of the Foreign Tax Credit (FTC) due to the late filing of Form No. 67, affirming its mandatory nature under Rule 128. The Tribunal emphasized the necessity of filing the form within the prescribed timeframe for verification purposes. Regarding the rectification order demanding additional tax payment, the Tribunal noted its issuance without a Document Identification Number (DIN) and directed a comprehensive review alongside the pending appeal against the ex-parte assessment order. The Tribunal did not specifically rule on the applicability of Double Taxation Avoidance Agreement (DTAA) provisions, focusing instead on procedural compliance. Case-Laws Income Tax Fri, 29 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762492