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Income Tax : The Tribunal ruled that delayed filing or incorrect disclosure in Form 67 does not automatically disentitle an assessee from claim...
Income Tax : The ITAT Kolkata held that delayed filing of Form No. 67 is only a procedural defect and cannot deprive an assessee of Foreign Tax...
Income Tax : The ITAT Kolkata held that delayed filing of Form No. 67 cannot deprive an assessee of Foreign Tax Credit under Section 90 and the...
Income Tax : ITAT Hyderabad held that CPC cannot make adjustments under Section 143(1)(a) without issuing prior intimation to the assessee as m...
Income Tax : The Delhi ITAT held that belated filing of Form No. 67 is only a procedural lapse and cannot extinguish substantive Foreign Tax Cr...
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The Tribunal ruled that delayed filing or incorrect disclosure in Form 67 does not automatically disentitle an assessee from claiming Foreign Tax Credit. Substantial justice must prevail over technical procedural defects.
The ITAT Kolkata held that delayed filing of Form No. 67 is only a procedural defect and cannot deprive an assessee of Foreign Tax Credit under Section 90 and the India-USA DTAA.
The ITAT Kolkata held that delayed filing of Form No. 67 cannot deprive an assessee of Foreign Tax Credit under Section 90 and the India-UK DTAA. The Tribunal treated the delay as a procedural defect.
ITAT Hyderabad held that CPC cannot make adjustments under Section 143(1)(a) without issuing prior intimation to the assessee as mandated by law. The Tribunal quashed the tax adjustment denying concessional tax benefits because the mandatory opportunity of response was not provided.
The Delhi ITAT held that belated filing of Form No. 67 is only a procedural lapse and cannot extinguish substantive Foreign Tax Credit rights under sections 90/90A/91 and applicable DTAAs. The Tribunal directed verification and grant of FTC where the form was filed before completion of assessment proceedings.
High Court held that consideration received on transfer of self-generated trademarks before 1 April 2002 was not taxable as capital gains because no ascertainable cost of acquisition existed, making computation provisions unworkable.
The Tribunal held that FTC claims cannot be rejected solely due to incomplete foreign tax return filing. The key takeaway is that authorities must verify available and subsequent evidence before denying relief.
The issue was denial of FTC due to delayed filing of Form 67. ITAT held that delay is procedural and directed authorities to grant credit after verification.
The tribunal examined whether delayed filing of Form 67 bars foreign tax credit. It held that filing before completion of assessment is sufficient, allowing the credit.
ITAT Pune rules that delay in filing Form 67 is a procedural lapse and cannot deny Foreign Tax Credit under Section 90; directs AO to grant ₹2.74 lakh FTC after verification, upholding substantive relief despite delay.
