The ITAT Hyderabad held that delayed filing of Form No. 67 cannot result in denial of foreign tax credit under Section 90. It ruled that the filing requirement is directory and cannot override the substantive benefit available under the DTAA.
The ITAT Hyderabad held that delayed filing of Form 67 does not justify denial of Foreign Tax Credit under the India–USA DTAA. It ruled that Rule 128(9) is directory and cannot override the substantive treaty benefit.
The ITAT Kolkata held that foreign tax credit cannot be denied merely because Form 67 was filed after the prescribed due date. It ruled that the filing requirement is procedural and does not extinguish the substantive claim.
The ITAT remanded the foreign tax credit claim to the CIT(A) after noting that the assessee had subsequently furnished the documents required under Rule 128. The appellate authority was directed to reconsider the claim on merits after granting a hearing.
The Supreme Court held that Mediclaim reimbursements cannot be deducted from compensation awarded under the Motor Vehicles Act because the two arise from different legal sources. The ruling clarifies that contractual insurance benefits earned through premium payments do not reduce statutory compensation payable for motor accident claims.
The ITAT Delhi held that a common satisfaction note covering multiple assessment years without year-wise incriminating material could not validly confer jurisdiction under Section 153C. It consequently quashed the assessment.
The Supreme Court set aside High Court judgments quashing reassessment notices after noting that the Finance Act, 2026 introduced clarificatory amendments affecting the competence of Assessing Officers. The matters were remanded for fresh consideration, leaving all legal issues open.
The SC declined to interfere with the Delhi High Court ruling after the Revenue acknowledged dismissal of similar SLPs. The High Court held that Section 153C proceedings cannot continue where the jurisdictional AO fails to identify year-specific incriminating material.
The ITAT Delhi held that the Assessing Officer failed to record that the seized material had a bearing on the determination of the assessees total income, rendering the Section 153C proceedings invalid. The assessments for multiple years were consequently quashed.
The ITAT Delhi held that a single satisfaction note covering multiple assessment years without identifying year-wise incriminating material could not confer valid jurisdiction under Section 153C. It consequently quashed the assessment.
