Foreign Tax Credit requires evidence of settlement, proof of payment and an undertaking within six months of dispute resolution.
Foreign Tax Credit (FTC) is allowed for disputed foreign tax only if, within six months from the end of the month in which the dispute is finally settled, the assessee furnishes evidence of settlement, evidence that the tax liability has been discharged by the assessee, and an undertaking that no refund in respect of that amount has been or will be claimed.

Foreign tax definition determines FTC scope: DTAA-covered taxes apply, otherwise income-tax-type foreign levies qualify for credit.
Definition of foreign tax for Foreign Tax Credit under Rule 128: where a DTAA exists, foreign tax is the tax covered by that DTAA; where no DTAA exists, foreign tax is the tax payable under the foreign country's law in the nature of income-tax as defined in the statutory explanation, including excess profits tax or business profits tax charged on profits by central or local authorities.

Foreign tax credit proportionate allocation ensures foreign tax relief is apportioned when income is taxed across multiple years.
Foreign tax credit under the Income tax Rules operates on a proportionate allocation principle when the same income is taxable in more than one year; the credit entitlement must be apportioned across the years in which the income is offered to tax so that relief for foreign taxes corresponds to the portion of income taxed in each year.

Foreign tax credit allowed when foreign tax corresponds to income offered or assessed to tax in India in the same year.
Foreign tax credit is available to Indian residents for tax paid in a foreign country or specified territory, and is allowed only in the year when the corresponding income is offered to tax or assessed to tax in India, creating a temporal link between domestic taxation of the income and recognition of the foreign tax credit.

Advance Pricing Agreement requires modified returns and extends reassessment deadlines for affected assessment years by tax authorities.
Entry into an Advance Pricing Agreement fixing the arm's length price requires the taxpayer to file a modified return for each affected assessment year within three months from the end of the month in which the APA is executed. If an assessment was already completed, the Assessing Officer must reassess under the APA and complete that reassessment within one year from the end of the financial year in which the modified return is filed. If the assessment was pending, the Assessing Officer may complete it within an extended timeframe permitted for APA-related assessments.

PAN requirement for life insurance premium payments: quoting PAN mandatory when annual premiums meet statutory threshold.
A payer must quote PAN when annual payments of life insurance premium to an insurer aggregate to Rs. 50,000 or more, the aggregation determining whether the PAN quoting obligation is triggered as a compliance mechanism for identification and reporting of premium payments.

PAN requirement for mutual fund and share deposits triggers mandatory identification and reporting when payments reach the statutory threshold.
Quoting a Permanent Account Number (PAN) is mandatory for deposits into mutual funds and for share purchases when the payment amount is fifty thousand rupees or more, under the PAN provisions and implementing rules governing income-return and reporting obligations.

PAN requirement for foreign travel payments: cash disbursements above prescribed limit require PAN for travel, tour, or currency purchases.
A PAN must be furnished where a single-instance cash payment connected with travel to a foreign country exceeds the prescribed cash threshold; this covers cash payments for fare, payments to travel agents or tour operators, payments to authorized persons under foreign exchange law, and purchases of foreign currency, while excluding travel to neighbouring countries and specified pilgrimage locations.

Permanent Account Number requirement: PAN is mandatory for opening bank accounts under income tax rules with no monetary threshold.
Permanent Account Number (PAN) is mandatory for opening a bank account under the income tax statutory framework and implementing rules; the requirement applies generally and the source does not specify any monetary threshold limiting the obligation, reflecting PAN's function as an identification and compliance mechanism in return of income and assessment procedure contexts.

PAN requirement for securities transactions mandates furnishing PAN for deposits exceeding prescribed threshold to enable identity verification.
A PAN furnishing requirement applies to sale and purchase of securities: where consideration in a securities transaction exceeds the statutory high-value threshold, the person transacting must furnish their Permanent Account Number to the counterparty, implementing identity verification and enabling tax reporting obligations under the income-tax rules.

PAN requirement for time deposits: PAN must be furnished when a time deposit exceeds the prescribed regulatory threshold.
A PAN must be furnished when a depositor makes a time deposit with a bank, banking company, or banking institution that exceeds the prescribed monetary threshold; this imposes an identification and reporting obligation under the income tax PAN provisions and rules.

PAN requirement for immovable property transactions: PAN must be furnished where property value meets the statutory threshold.
A Permanent Account Number (PAN) must be furnished for sale or purchase of immovable property when the transaction reaches the statutory value threshold, as part of PAN-related obligations in return of income and assessment procedure; this requirement applies to parties to the transaction to ensure tax documentation and compliance.

Right to file revised return: no prior permission required and permission-application cannot substitute for revision.
No prior permission is required to file a revised return; the assessee has a right to submit a revised return. An application framed as seeking permission to revise the originally filed return cannot be treated as, or substitute for, a valid revised return, and therefore does not meet the statutory mechanism for revision.

Revised return can be filed multiple times within the limitation period when omissions or errors are discovered in the original filing.
An assessee may file a revised return multiple times so long as each revision is within the applicable limitation period and corrects an omission or wrong statement discovered in the earlier return, permitting successive amendments prior to expiry of the statutory time bar.

Revised return substitutes the original return, while mere corrections leave the original filing intact for assessment.
A validly filed revised return withdraws and substitutes the original return for assessment purposes; corrections or amendments made to a filed return without filing a revised return do not change the filing's character and therefore do not effect such substitution.

Auditor's report: may be filed with a revised return to rectify omission from the original tax return.
Where an assessee obliged to furnish an auditor's report with its income tax return fails to submit it with the original filing, the auditor's report may be furnished subsequently with the revised return, permitting rectification of that omission under the return amendment regime.

Assessment under section 143(1) not an assessment; revised return filed after intimation remains valid for consideration.
An intimation issued under section 143(1) is procedural and does not constitute a formal assessment; therefore a revised return filed after such an intimation but within the statutory period must be treated as duly filed and considered by the Assessing Officer.

Share premium taxation under Section 56(2)(viib): excess consideration over fair market value is taxable on closely held companies.
Taxability of share premium for a closely held company turns on whether consideration per share exceeds fair market value; if FMV exceeds consideration (FMV 42, consideration 40) no tax arises, whereas if consideration exceeds FMV (consideration 40, FMV 31) the excess per share (9) is taxable under the provision governing share premium receipts.

Taxability of discounted transfers to closely held companies: listed company shares are excluded from gift inclusion, so not taxable.
Receipt of listed public company shares by a closely held company for consideration below fair market value does not attract tax under the provision addressing gifts to firms and closely held companies, because shares of a listed company are excluded from that inclusion and therefore are not characterized as taxable income from other sources under that rule.

Taxability of gifts: transfers from a partnership firm to an individual are taxable when the firm is not a relative.
A gift of immovable property from a partnership firm to an individual is taxable under the gift provisions because a partnership firm is not a "relative" even if the partners are relatives; the stamp duty valuation of the plot is noted for valuation reference.