SANJEEV SIVASANKARAN MENON,CHENNAI vs. DCIT, CIRCLE-3(3)(1), BANGALORE

ITA 200/BANG/2026Status: DisposedITAT Bangalore24 September 2026AY 2019-204 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the delay in filing Form 67 is a technical violation and should not result in the denial of substantive Foreign Tax Credit. The issue is covered by a coordinate bench decision in the assessee's own case.

What were the facts?

The assessee claimed Foreign Tax Credit for tax paid in the USA on dividend income from ESOP shares. The credit was denied by the CPC due to delayed filing of Form 67, which was upheld by the CIT(A).

What were the issues?

Whether the delay in filing Form 67 can lead to the denial of Foreign Tax Credit, and if the assessee is entitled to claim credit for taxes paid in the USA.

Which sections of the Income-tax Act were involved?

Section 139(1),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K.

PER SHRI WASEEM AHMED, ACCOUNTANT MEMBER:

The present appeal filed by the assessee for A.Y. 2019-20 is against the order of the Ld. Commissioner of Income Tax (Appeals) [hereafter “Ld. CIT(A)”] passed u/s 250 of the Income Tax Act, 1961 (hereafter “the Act”) dated 03.12.2025. 2. In the memo of appeal, the assessee has raised various grounds, which are interconnected and revolve arou

The order continues below.

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