Income Tax : Understand the statutory time limits for filings, applications, approvals, and settlement processes under the Income-tax Act, incl...
Income Tax : The AIS is a comprehensive statement providing all tax and financial transaction details, including TDS, SFT, and external data, t...
Company Law : Understand Sections 89 and 90 of the Companies Act, 2013, focusing on legal ownership declarations and significant beneficial owne...
CA, CS, CMA : Discover the complexities of tax compliance for freelancers and gig workers, from understanding income sources to navigating legal...
Income Tax : Understand the concept of Updated Return under the Income-tax Act, its necessity, tax implications, and filing process. Get insigh...
Income Tax : The Central Government have notified the “Hong Kong Special Administrative Region of the People’s Republic of China” as ‘s...
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...
The issue was whether late filing of Form 67 bars foreign tax credit under DTAA. ITAT held that FTC is a substantive right under section 90 and cannot be denied for a procedural delay.
Uttarakhand High Court held that order of the Competent Authority granting sanction or approval or refusing to grant sanction or approval u/s 151 of the Income Tax Act of 1961 is neither a revisable order, nor an appealable order.
Tribunal held that a company engaged in diversified IT consultancy and transformation services cannot be compared with a routine software development service provider
The ITAT held that late filing of Form 67 cannot defeat a valid FTC claim. The ruling clarifies that procedural delays do not override substantive treaty rights.
The dispute centered on whether DRP directions allow completion of assessment beyond statutory time limits. The Tribunal clarified that section 144C does not create an independent limitation period. Procedural timelines cannot defeat the mandatory bar under section 153.
ITAT Mumbai ruled that ancillary software support services did not constitute FTS under the India–Singapore DTAA, deleting a ₹482.77 crore addition due to failure of the make available test.
The tribunal held that assessments completed through the DRP mechanism remain subject to the outer time limit prescribed under section 153. The key takeaway is that section 144C does not extend or override statutory limitation periods.
The Tribunal held that a final assessment passed after the expiry of Section 153 is invalid, even if it follows DRP directions. The is that limitation under Section 153 remains mandatory and cannot be bypassed through the DRP route.
The ITAT Hyderabad held that section 144C cannot override outer time limits under section 153. Assessments passed beyond statutory deadlines are void, reinforcing strict compliance with limitation periods.
ITAT Hyderabad held that the final assessment under section 143(3) r.w.s 144C(13) passed beyond statutory time limits is invalid. The ruling reinforces that the outer limit under section 153 cannot be extended, emphasizing strict compliance with limitation provisions.
