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Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
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Income Tax : Notification No. 3/2011 - Income Tax WHEREAS the annexed Agreement among the Governments of SAARC (South Asian Association for Re...
Income Tax : Notification No. 86/2010-Income Tax Whereas, an Agreement and the Protocol between the Government of Republic of India and the Gov...
Income Tax : Notification No. 36/2010-Income Tax Whereas, an Agreement and the Protocol between the Government of Republic of India and the Gov...
Income Tax : Notification No. 25/2010-Income Tax In exercise of the powers conferred by Explanation 2 to section 90 of the Income-tax Act, 1961...
ITAT Ahmedabad held that denial of Foreign Tax Credit [FTC] on the ground that corresponding income has not been offered for tax in the year under appeal is not justifiable. Accordingly, FTC allowed.
ITAT Ahmedabad rules procedural delays in filing Form 67 cannot deny Foreign Tax Credit under Section 90 of the Income Tax Act. Relief granted to the taxpayer.
ITAT Ahmedabad directs CIT(A) to decide the denial of Foreign Tax Credit (FTC) due to delay filing of Form No. 67 to be decided with other pending appeal of the same assessment year. Accordingly, matter remitted to CIT(A).
Hire charges of a vessel did not constitute ‘Royalty’ as it was in the nature of business income and as there was no Permanent Establishment therefore, no taxability arose on account of business income.
A person residing in USA desirous of transferring money to an individual or an entity in India, approaches a branch or an outlet of the assessee and transfers the money in USDs, together with the charges prescribed by the respondent-assessee.
Although Rule 128(9) requires Form 67, assessee’s compliance within this rule during the rectification stage demonstrated a good faith or effort to fulfil procedural requirement.
ITAT Kolkata held that since filing of Form 67 is procedural in nature, delay in filing of the same cannot be the reason for denial of relief under section 90 of the Income Tax Act. Accordingly, appeal allowed.
Despite late filing of Form 67, assessee deserved the credit for taxes paid in Nepal since the provisions of DTAA (in this case DTAA with Nepal) had an overriding effect over other provisions of the Act.
The assessee filed his return of Income on 27.08.2019. After filing the return, assessee received intimation u/s 143(1) of the Act dated 23.03.2021 and found that relief under section 90 of the Act had not been allowed amounting to Rs 73,658/-.
ITAT Bangalore held that delay of 1809 days in filing of an appeal condoned since reasonable cause shown for the delay. Accordingly, appeal allowed and AO directed to allow Foreign Tax Credit after due verification of Form 67.
