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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.
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.
