Relief of foreign tax credit u/s 90 - non compliance of ...

Income Tax

September 21, 2022

Relief of foreign tax credit u/s 90 - non compliance of procedural requirement - As the assessee has vested right to claim the FTC under the tax treaty and the same cannot be disallowed for mere delay in compliance of a procedural provision. - there were no reasons with the tax authorities for making disallowance when the said Form 67 was very much available with the AO at the time of framing the assessment order. - AT

View Source

← Previous Next →

Relief of foreign tax credit u/s 90 - non compliance of ...

Income Tax

September 21, 2022

You may also like:

Entitlement to foreign tax credit - The Tribunal concludes that the filing of Form 67 is a procedural requirement and should be construed as directory rather than...

Foreign Tax Credit u/s. 90 - Assessee did not file Form 67 at the time of filing of her return of income - Referring to established case law, the Tribunal affirmed that...

Relief u/s. 90 - Foreign Tax Credit (FTC) - In the instant case, the delay in filing of the FTC certificate in Form-67 was explained to be due to non receipt of the tax...

Relief u/s. 90 / 90A - foreign tax credit - the assessee has paid foreign tax credit in USA and has filed his return of income U/s. 139(4) - we consider it deemed to be...

Relief u/s 90 - foreign tax credit - disallowance of FTC in case of delay in filing Form No. 67 - the assessee is eligible for foreign tax credit, as she has filed form...

Foreign tax credits u/s 90/90A - Rule 128 is a procedural provision and not a mandatory provision - Rule 128 nowhere provides that if the said Form 67 is not filed...

Claim of foreign tax credit (FTC) u/s 90 or u/s 91 - Applicability or Rule 128 with retrospective effect - In view of Singapore Taxation Laws the income in question is...

Disallowance of foreign tax credits - failure to the requisite documents as specified u/s 128(8) - Considering the fact that the assessee is stated to be in possession...

Foreign tax credit claimed under Article 24 of India- UK DTAA read with Section 90 - assessee who is a resident of India and has derived from salary which has suffered...

Eligibility of Foreign tax credit - delay in compliance of a procedural provision - delay in filing Form No.67 - Assessee has vested right to claim the FTC under the tax...

Denial of foreign tax credit u/s 90/90A due to delay in filing Form no.67 - Mere delay in filing Form No. 67 as per the provisions of Rule 128(9), as they stood during...

Foreign tax credit u/s 90/90A - delay in filing Form no.67 - mere delay in filing Form No. 67 as per the provisions of Rule 128(9), as it stood during the year under...

Denial of foreign tax credit u/s 90/90A due to delay in filing Form no.67 - mere delay in filing Form No. 67 as per the provisions of Rule 128(9), as they stood during...

Refund of CENVAT Credit - In the present case, the appellant would be eligible to avail credit but for the introduction of GST law. The said right cannot be frustrated...

Salary income from foreign company for short term foreign assignment - The Tribunal held that, the assessee possesses tax residency certificate of United kingdom for a...

Quick Updates: