SHIPIJ RATHORE,INDORE vs. INCOME TAX OFFICER 1(2), INDORE

ITA 557/IND/2025Status: DisposedITAT Indore19 February 2026AY 2021-202215 pages
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What did the Tribunal hold?

The Tribunal held that the filing of Form No. 67 is a directory requirement and not mandatory. A bona fide technical mistake in selecting the incorrect assessment year for Form No. 67 should not lead to denial of legitimate relief.

What were the facts?

The assessee filed her return of income for AY 2021-22 claiming foreign tax credit (FTC). The FTC was denied as Form No. 67 was not filed. The assessee had mistakenly filed Form No. 67 for AY 2020-21 instead of AY 2021-22 on the same day she filed her return.

What were the issues?

Whether the denial of foreign tax credit due to a bona fide mistake in filing Form No. 67 for the incorrect assessment year is justified, and if the filing of Form No. 67 is a mandatory condition for claiming FTC.

Which sections of the Income-tax Act were involved?

Section 90,Section 90A,Section 143(1),Section 154,Section 139(1)

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## आयकर अपीलीय अिधकरण**,** इंदौर Ɋायपीठ**,** इंदौर **IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE**

#### **BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M. JOSHI, JUDICIAL MEMBER**

## **ITA No.557/Ind/2025**

**Assessment Year:2021-22**

| Shipij<br>Rathore,<br>126,<br>Swami<br>Dayanand<br>Nagar,<br>Indore | | बनाम/<br>Vs. | ITO<br>1(2)<br>Indore | |---------------------------------------------------------------------|----------------------------------------|--------------|-----------------------| | (Assessee/Appellant) | | | (Revenue/Respondent) | | PAN:<br>AYJPR7888L | | | | | Assessee<br>by | Shri<br>Aditya<br>Bhatt,<br>AR | | | | Revenue<br>by | Shri<br>Ashish<br>Porwal,<br>Sr.<br>DR | | | | Date<br>of<br>Hearin

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