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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...
Income Tax : The Income-tax Act, 1961 (the Act) provides that the Central Board of Direct Taxes may prescribe rules specifying the procedure fo...
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...
Bombay High Court held that application for NIL withholding tax certificate rightly rejected since matter of taxability of fees for technical services [FTS] rendered from China for previous assessment years is already pending before ITAT. Accordingly, writ petition is disposed of.
The judgment confirms that income from offshore equipment supply is not taxable where transactions occur outside India. The liaison office was also held not to create a taxable presence. The case highlights limits of tax jurisdiction over cross-border supplies.
The Tribunal emphasized that procedural rules like Form 67 filing timelines are not meant to deny legitimate FTC. It directed the AO to grant credit after verifying evidence. The case highlights the primacy of DTAA provisions.
The issue was incorrect computation of interest without reducing foreign tax relief. ITAT held that relief under sections 90/90A must be deducted before calculating interest under sections 234A, 234B, and 234C.
The Tribunal emphasized that procedural lapses should not defeat substantive tax relief. It held that Form 67 filed during rectification proceedings is valid compliance, allowing reconsideration of FTC claim.
The Tribunal restored the penalty matter as the quantum addition was sent back to the AO. It held that penalty must follow the outcome of reassessment proceedings.
The Tribunal condoned a delay of 615 days after finding that the assessee was actively pursuing rectification remedies under Section 154. It held that such bona fide conduct constitutes sufficient cause and delay cannot be treated as negligence.
ITAT held that late filing of Form 67 is only a procedural lapse and not a ground to deny FTC. The matter was remanded for verification and grant of eligible credit.
The tribunal held that capital gains from share buyback are not taxable in India under treaty provisions. It clarified that such transactions qualify as corporate reorganisation. The key takeaway is that DTAA benefits override domestic tax provisions when more beneficial.
Tribunal held that technical handling income is covered under Article 8 of India–France DTAA. It ruled that such income arises from operation of aircraft in international traffic and is not taxable in India.
