Topic
ITAT Bangalore holds that a delayed Form 67 submission does not automatically disqualify a taxpayer from claiming foreign tax credit under Section 90, provided the credit was claimed in the return. The ruling clarifies that procedural delays in filing Form 67 should not override substantive entitlement to relief under Double Taxation Avoidance Agreements.
The Andhra Pradesh High Court has ruled that a certified copy of an FIR, already declared false by a criminal court, lacks evidentiary value and cannot be admitted in a civil suit under CPC Order VIII Rule 14(3), regardless of belated filing. This reinforces that judicial integrity trumps procedural leniency when documents are fundamentally unreliable, affecting litigants seeking to rely on tainted police records in property disputes.
ITAT Delhi rules that delayed filing of Form 10CCB under Section 80IAC does not invalidate tax deductions if submitted before assessment finalisation, reinforcing the principle of substantial compliance over procedural technicalities. This precedent protects startups and eligible businesses from losing tax benefits due to minor filing delays.