TANAGUNDI BHOGESWARA PRASAD,BANGALORE vs. ASSITANT DIRECTOR OF INCOME TAX, BANGALORE

ITA 1435/BANG/2026Status: DisposedITAT Bangalore22 September 2026AY 2020-215 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the substantive right to claim foreign tax credit should not be denied due to belated filing of Form No. 67, especially in the first year of dealing with foreign income. The appeal was allowed with a direction to file Form No. 67.

What were the facts?

The assessee claimed foreign tax credit for income earned in Norway. The claim was denied because Form No. 67 was not filed along with the return. The CIT(A) dismissed the appeal as barred by limitation.

What were the issues?

Whether foreign tax credit can be denied solely for belatedly filing Form No. 67, and whether the appeal before CIT(A) was rightly dismissed on limitation grounds.

Which sections of the Income-tax Act were involved?

Section 90,Section 154,Section 250

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 is filed by Tanagundi Bhogeswara Prasad (the assessee/appellant) for assessment year 2020–21 against the appellate order dated 22 January 2026 passed by the Commissioner of Income Tax (Appeals), Agra (the learned CIT(A)). By that order, the learned CIT(A) dismissed in limine the assessee’s appeal against the rectification order passed under section 154 o

The order continues below.

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