TANYA SONEJA,GWALIOR vs. INCOME TAX OFFICER, WARD INTL. TAXATION 1(2), BENGALURU

ITA 1314/BANG/2026Status: DisposedITAT Bangalore22 September 2026AY 2018-195 pages
AI SummaryRemanded

What did the Tribunal hold?

The ITAT condoned the delay in filing the appeal before it, accepting the reason of the authorized representative's illness. The tribunal then restored the entire appeal to the Assessing Officer to re-examine the foreign tax credit claim, directing the assessee to substantiate it with relevant documents including Form 67.

What were the facts?

The assessee's foreign tax credit claim of ₹1,47,713 was disallowed by the Central Processing Centre (CPC) under Section 143(1). The CIT(A) dismissed the assessee's appeal due to a delay in filing, without considering the reasons for the delay.

What were the issues?

The key legal issues were the condonation of delay in filing appeals at both the CIT(A) and ITAT levels, and the eligibility of the assessee for foreign tax credit under Section 90 of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 143(1),Section 90

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SANDEEP SINGH KARHAIL

PER SHRI PRASHANT MAHARISHI, VICE PRESIDENT

01.

This appeal has been filed by Tanya Soneja, [ the Assessee/ Appellant], for assessment year 2018–19 against the appellate order dated 22 October 2025 passed by the Joint Commissioner of Income Tax (Appeals)-2, Kolkata [the learned CIT(A)]. By that order, the learned CIT(A) dismissed the assessee’s appeal against the intimation issued under section 143(1) of the Income-tax Act on 14 May 2020, whe

The order continues below.

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