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“Section 119(2)”

Section References (mined)Section 119Section 119(2)554 judgments

The decision most relied on for Section 119(2) is Commissioner of Customs v. Indian Oil Corporation Ltd. (267 ITR 272), cited in 501 judgments on BharatTax.

Leading authorities on Section 119(2)

Commissioner of Customs v. Indian Oil Corporation Ltd.
267 ITR 272 · 2004 · Supreme Court
501
citing judgments

CBDT and CBEC circulars, along with administrative instructions, are binding on departmental authorities, who must not act in contravention of them. However, these circulars and instructions are not binding on courts or assessees.

UCO Bank v. CIT
237 ITR 889 · 1999 · Supreme Court
486
citing judgments

CBDT circulars and instructions, while not binding on courts or assessees, are strictly binding on income-tax departmental authorities, who cannot act in contravention of them.

Gajanan Constructions v. DCIT
74 Taxmann.com 6 · 2016 · ITAT
465
citing judgments

Late fees under section 234E can only be levied prospectively from June 1, 2015. Levying late fees for periods prior to this date is not permissible.

CIT v. G.M. Knitting Industries (P.) Ltd.
376 ITR 456 · 2015 · Supreme Court
221
citing judgments

The requirement to file a certificate or form (e.g., Form 10CCB, 10-IC) along with the return of income for claiming a deduction (e.g., under sections 80-IB, 115BAA) is directory regarding its timing. Such a deduction is allowable if the requisite form is filed before the final order of assessment, as procedural requirements should not override substantive benefits.

CIT v. Gujarat Oil & Allied Industries
201 ITR 325 · 1993 · High Court
195
citing judgments

The requirement to file an audit report along with the income tax return, as specified in provisions like Section 80J(6A) or 80-IA(7), is directory and not mandatory. Substantial compliance is achieved if the audit report is submitted at any time before the assessment is framed or completed, and benefits should not be denied merely due to a delay in furnishing it.

PCIT v. Wipro Ltd.
140 Taxmann.com 223 · 2022 · Supreme Court
192
citing judgments

Exemption provisions under Chapter III, such as Section 10B(8), must be interpreted strictly, and any claim for such exemptions must be made in the return of income. The principles governing Chapter III (incomes not forming part of total income) differ from those for Chapter VIA (deductions in computing total income).

Setty & Others vs. State of Karnataka (7) (1996) 1 SCC 345- Secretary Government of Madras v. P.R. Sriramulu
4 SCC 720 · 2008 · Reported
145
citing judgments

The validity of Section 234E of the Income Tax Act, 1961, inserted by the Finance Act, 2012, is examined by the court.

CIT v. Contimeters Electricals (P.) Ltd.
317 ITR 249 · 2009 · High Court
140
citing judgments

The requirement to file an audit report along with the return of income under section 80-IA(7) and similar provisions is directory, not mandatory. Such a report suffices if filed at any time before the assessment is framed.

Judgments citing Section 119(2)

DE vs. Than Trust, Vadodara

The appeal of the assessee is allowed

ITA 1729/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2016-17

Bench: Ms. Suchitra Kamble

For Appellant: Shri Parin S Shah, ARFor Respondent: Shri Umesh Kumar Agarwal, Sr. D.R
Section 11Section 119(2)(b)Section 12ASection 143(1)Section 154Section 234A

assessee trust filed rectification under Section 154 of the Act and subsequently filed Form 10B along with condonation of delay application under Section 119(2)(b) of the Act. 4. The PCIT (Exemption) rejected the condonation application and therefore, the assessee filed the appeal before

Jagruk Mahila Gramudhyog Sansthan, Aligarh vs. Commissioner Exemption Circle, Ghaziabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 8948/DEL/2025[2021-22]Status: DisposedITAT Delhi09 Apr 2026AY 2021-22

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] Jagruk Mahila Gramudhyog Commissioner Exemption Circle, Sansthan, Cgo Complex, Ghaziabad, Ews-22, Ada Colony, Vs Uttar Pradesh-201009 Ramghat Road, Aligarh, Uttar Pradesh-202001 Pan-Aaaaj7483P Assessee Revenue Assessee By Ms. Madhulika Raghav, Ar Revenue By Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing 23.03.2026 Date Of Pronouncement 09.04.2026

Section 10BSection 119(2)(b)Section 12ASection 139Section 143(1)Section 154Section 250

erred in the fact that the appellant gets the condonation of delay of filing of Form 10B from the CIT (Exemptions), Lucknow under section 119(2)(b) via order No ITBA/COM/F/17 /2024-25/1074553867{1) dated 17.03.2025. 6. That the arbitrary disallowance made by the Ld. CIT (A) in the income ... Counsel submitted that the delay in filing of Form 10B was condoned by CIT(E), Lucknow, vide order dated 17.03.2025 under section 119(2)(b) of the Act. The ld. CIT(A) dismissed assessee’s appeal holding that Return of Income was delayed and hence exemption cannot be granted

Karma Ecotech Pvt. Ltd, Delhi vs. DCIT, Cirle 13(1), New Dlhi, New Delhi

In the result, the appeal of the assessee is allowed

ITA 7431/DEL/2025[2024-25]Status: DisposedITAT Delhi18 Mar 2026AY 2024-25

Bench: Shri Raj Kumar Chauhan, Hon’Ble & Smt. Renu Jauhri, Hon’Ble

Section 119(2)Section 119(2)(b)Section 143(1)Section 80I

ITA No. 7431_DEL_2025_Karma Ecotech Pvt Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, E: NEW DELHI

Tathagat, New Delhi vs. AO Centralized Processing Center, Income Tax Depatment Bengaluru

In the result, the appeal of Revenue is dismissed

ITA 7273/DEL/2025[2022-2023]Status: DisposedITAT Delhi18 Mar 2026AY 2022-2023

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 119Section 119(2)(b)Section 12ASection 143(1)

authorized jurisdictional Commissioner/Director of Income- tax to condone delay in filing form 10B, and Commissioner (Appeals) did not have any power under section 119(2)(b) to condone delay in filing Form 10B. Thus, Commissioner (Appeals) dismissed assessee's appeal holding that assessee had remedy before jurisdictional Commissioner/ Pr. Commissioner/Director ... have not made any application for condonation of delay in filing Form 10B before concerned Pr. Commissioner/Commissioner/Director of Income-tax as provided under section 119(2)(b). Whether there was no infirmity in order passed by Commissioner (Appeals)-hold, Yes (Paras 6.2 and 6.3) [In favour of revenue." Tathagat

Tathagat, New Delhi vs. AO Centralized Processing Center, Income Tax Depatment Bengaluru

In the result, the appeal of Revenue is dismissed

ITA 7272/DEL/2025[2021-2022]Status: DisposedITAT Delhi18 Mar 2026AY 2021-2022

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 119Section 119(2)(b)Section 12ASection 143(1)

authorized jurisdictional Commissioner/Director of Income- tax to condone delay in filing form 10B, and Commissioner (Appeals) did not have any power under section 119(2)(b) to condone delay in filing Form 10B. Thus, Commissioner (Appeals) dismissed assessee's appeal holding that assessee had remedy before jurisdictional Commissioner/ Pr. Commissioner/Director ... have not made any application for condonation of delay in filing Form 10B before concerned Pr. Commissioner/Commissioner/Director of Income-tax as provided under section 119(2)(b). Whether there was no infirmity in order passed by Commissioner (Appeals)-hold, Yes (Paras 6.2 and 6.3) [In favour of revenue." Tathagat

Tathagat, New Delhi vs. AO Central Processing Center, Income Tax Department

In the result, the appeal of Revenue is dismissed

ITA 7271/DEL/2025[2020-2021]Status: DisposedITAT Delhi18 Mar 2026AY 2020-2021

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 119Section 119(2)(b)Section 12ASection 143(1)

authorized jurisdictional Commissioner/Director of Income- tax to condone delay in filing form 10B, and Commissioner (Appeals) did not have any power under section 119(2)(b) to condone delay in filing Form 10B. Thus, Commissioner (Appeals) dismissed assessee's appeal holding that assessee had remedy before jurisdictional Commissioner/ Pr. Commissioner/Director ... have not made any application for condonation of delay in filing Form 10B before concerned Pr. Commissioner/Commissioner/Director of Income-tax as provided under section 119(2)(b). Whether there was no infirmity in order passed by Commissioner (Appeals)-hold, Yes (Paras 6.2 and 6.3) [In favour of revenue." Tathagat

Electronfab Engineering Pvt Ltd, Seepz Sez Mumbai vs. Income Tax Officer, Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 4828/MUM/2025[2024-25]Status: DisposedITAT Mumbai16 Mar 2026AY 2024-25

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Nishit Gandhi, Advocate (virtually appear) & Mrs. Usha DalalFor Respondent: Shri Himanshu Joshi (Sr. DR)
Section 115BSection 115JSection 139(5)Section 139(9)Section 143(1)Section 250

original return then enter Receipt No. (DD/MM/YYYY) If filed, in response to a notice u/s 139(9)/142(1)/148/153A/153C or order under section 119(2)(b), enter unique number /Document Identification Number (DIN) and date of such notice/Order, or if filed u/s 92CD enter date of advance pricing agreement ... Finance Department of Revenue Central Board of Direct Taxes " Circular No.6/2022 New Delhi, the 17th March, 2022 Sub: Condonation of delay under section 119(2)(b) of the Income Tax Act, 1961 in filing of Form 10-IC for assessment year 2020-21 - Reg Section 115BAA of the Income

K 1364 Veerasolapuram Primary Agricultural Co Op Credit Society Limited, Tirupur vs. The Income Tax Officer, Ward 1(4) Tirupur, Tirupur

In the result, the appeal filed by the assessee is dismissed

ITA 3790/CHNY/2025[2019-20]Status: DisposedITAT Chennai13 Mar 2026AY 2019-20

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.3790/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 K 1364 Veerasolapuram Primary Vs. The Income Tax Officer, Agricultural Co Op Credit Society Ward 1(4), Limited, Veerasolapuram Po, Tirupur. Kangayam Tk. Tiruppur, Tamil Nadu, 638701. [Pan:Aabak4255B] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. A. Vijayalakshmi, C.A. (Virtual) ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 17.02.2026 घोषणा की तारीख /Date Of Pronouncement : 13.03.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.10.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For Assessment Year 2019-20. 2. At The Outset, It Was Submitted By The Ld Ar Ms. A. Vijayalakshmi, C.A. That The Authorities Below, Ignoring The Petition Filed By The Assessee

For Appellant: Ms. A. Vijayalakshmi, C.A. (virtual)For Respondent: Ms. Gouthami Manivasagam, Addl. CIT
Section 119(2)(b)Section 139Section 80P(2)(a)

Vijayalakshmi, C.A. that the authorities below, ignoring the petition filed by the assessee 2 I.T.A. No.3790/Chny/25 under section 119(2)(b) of the Income Tax Act, 1961 [“Act” in short], denied the exemption claimed under section 80P(2)(a)(i) of the Act. She referred to ground No.5 and prayed ... remand the matter to the file of Assessing Officer with the direction to await the result in the petition filed under section 119(2)(b) of the Act and decide this issue of claim under section 80P(2)(a)(i) of the Act. 3. The ld. DR Ms. Gouthami Manivasagam

Getinge Medical India Private Limited, Mumbai vs. DCIT 2(2)(1), Mumbai Maharashtra

In the result, appeal filed by the assessee stands partly allowed

ITA 4872/MUM/2024[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 115Section 115BSection 142(1)Section 143(2)Section 156Section 234ASection 270ASection 37Section 41Section 41(1)(a)

filing the relevant forms, the correct remedy available to the assessee in such a case is filing for condonation of delay under section 119(2)(b). The CBDT has already issued a circular No. 17 of 2024, dated 18-11-2024 (submitted during the course of the hearing), wherein ... which declined to condone the delay in filing of Form 10-B in respect of an educational trust, Hon'ble Court dealt with section 119(2)(b) and a circular vide which powers to condone delay were delegated to CITs. In para 18,19 and 20 Hon'ble Court noted

Roman Catholic Church of St. Joseph, Mumbai vs. ITO Ward 2(2), Mumbai

In the result, the Assessee’s Appeal is allowed, in the above terms

ITA 6930/MUM/2025[2023-24]Status: DisposedITAT Mumbai11 Mar 2026AY 2023-24

Bench: Shri Narender Kumar Choudhryshri Girish Agrawal

For Appellant: Ms. Vasanti Patel, & M.A.GohelFor Respondent: Shri Umashankar Prasad (Ld. CIT
Section 11Section 11(1)(a)Section 12ASection 139(1)Section 143(1)Section 250Section 44A

view of the foregoing discussion, we hereby quash and set aside the impugned order dated 30th January 2025 passed by Respondent No.1 under Section 119(2)(b) of the Act. 12. Now that the impugned order is quashed, we also hereby condone the delay in filing Form No.10B

Supertech Ev Limited, Jhajjar vs. ITO Exemption Ward, Rohtak

In the result the appeal of the assessee is allowed

ITA 6603/DEL/2025[2024-25]Status: DisposedITAT Delhi11 Mar 2026AY 2024-25

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2024-25 Supertech Ev Limited Vs. Adit, Cpc, Bengaluru/ Ito Plot No.150 Sector 16 Exemptions Ward Rohtak Phase 1 Bahadurgarh Jhajjar Haryana-124507 Pan No.Abjcs1671E (Appellant) (Respondent)

Section 115BSection 143(1)Section 154Section 234B

rejection of the condonation of delay in filing Form 10-IC are strongly supported by various judgments that widely interpret "genuine hardship" under Section 119(2)(b) of the Act. The Hon'ble Supreme Court in B.M. Malani (supra) emphasized that "genuine hardship" signifies "genuine difficulty" and requires a purposeful

Rai Sahab Bhaiyalal Dubey Educational and Medical Charitable Trust, Jabalpur vs. Income Tax Officer (Exemption), Jabalpur

In the result, the appeal is partly allowed for statistical purposes

ITA 186/JAB/2024[2020-21]Status: DisposedITAT Jabalpur10 Mar 2026AY 2020-21

Bench: Shri Anadee Nath Misshra

Section 11Section 11(2)Section 11ASection 12ASection 143(1)

issued by I.T.A. No.186/JAB/2024 Assessment Year:2020-21 10 the Board in Circular No. 16 of 2022 dated 19-07-2022 issued under Section 119(2)(b) by which the powers delegated to the Principal Chief Commissioner of Income Tax/Commissioner of Income Tax to condone the delay in filing Form

Amith Vishnav Gudimella, Hyderabad vs. ITO, Ward-12(1), Hyderabad

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 1705/HYD/2025[2020-21]Status: HeardITAT Hyderabad06 Mar 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1705/Hyd/2025 Assessment Year 2020-2021 Amith Vishnav The Income Tax Officer, Gudimella, Hyderabad. Ward-12(1), Pin – 500 008. Telangana. Vs. Hyderabad. Pan Aghpv2565J Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By Sri T Chaitanya Kumar, Advocate राज" व "ारा/Revenue By : Ms Reema Yadav, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03.03.2026 घोषणा की तारीख/Pronouncement: 06.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: MS Reema Yadav, Sr. AR
Section 143(1)Section 154Section 90Section 91

above, it is apparent that unless there is an order condoning the delay in filing Form No. 67 by the PCIT under Section 119(2)(b), such Form No.67 can't be taken into consideration and the relief u/s. 91 cannot be allowed by the Appellate Authority even if other

Rotary Club of Bombay Queens Necklace Charitable Trust, Mumbai vs. ITO Ward 2(2), Mumbai

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 8306/MUM/2025[2023-24]Status: DisposedITAT Mumbai06 Mar 2026AY 2023-24

Bench: Shri Anikesh Banerjee & Shri Bijayananda Prusethrotary Club Of Bombay Vs Ito (Exem.) Ward 2(2), Mumbai Queens Necklace Charitable Aayakar Bhawan, M.K. Road Trust Mumbai-400020 B 41/45, Paragon Centre, Pandurang Budhkar Marg, Worli, Mumbai-400013 Pan: Aaatr4200K Appellant Respondent

For Appellant: Shri Kishor PatelFor Respondent: Shri Bhagirath Ramawat (SR DR)
Section 11(1)(a)Section 12ASection 12A(1)(b)Section 139(1)Section 143(1)Section 143(1)(a)Section 250

attention to CBDT Circular No. 16 of 2024 dated 18.11.2024, wherein the Central Board of Direct Taxes (CBDT) directed condonation of delay under section 119(2)(b) of the Act for Assessment Year 2018–19 in respect of delay in filing Form No. 10B. However, it was pointed out that

Dy. Commissioner of Income-Tax Central Circle - 6(2), Mumbai vs. Tata Aig General Insurance Co. Ltd, Mumbai

Accordingly, Ground No.2 of the assessee is allowed

ITA 2403/MUM/2024[2018-19]Status: DisposedITAT Mumbai05 Mar 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)
Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI JAGADISH, ACCOUNTANT

Deputy Commissioner of Income Tax, Central Circle 6(2), Mumbai vs. Tata Aig General Insurance Co. Ltd, Mumbai

In the result the appeal of the revenue’s bearing ITA No

ITA 2398/MUM/2024[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)
Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

statutory powers under section 119 of the Income-tax Act, which are binding on the authorities in the administration of the Act. Under section 119(2)(a), however, the circulars as contemplated therein cannot be adverse to the assessee. Thus, the authority which wields the power for its own advantage

Tata Aig General Insurance Company Limited, Mumbai vs. Assistant Commissioner of Income-Tax-8(3)(1), Mumbai

In the result the appeal of the revenue’s bearing ITA No

ITA 1450/MUM/2024[2018-19]Status: DisposedITAT Mumbai05 Mar 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)
Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

statutory powers under section 119 of the Income-tax Act, which are binding on the authorities in the administration of the Act. Under section 119(2)(a), however, the circulars as contemplated therein cannot be adverse to the assessee. Thus, the authority which wields the power for its own advantage

Tata Aig General Insurance Company Limited (Tagic), Mumbai vs. Assessment Unit, Income-Tax Department

ITA 1432/MUM/2024[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)
Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND SHRI JAGADISH, ACCOUNTANT

Ntt Managed Services India Private Limited, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 1165/HYD/2025[2023-24]Status: HeardITAT Hyderabad04 Mar 2026AY 2023-24

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1165/Hyd/2025 Assessment Year 2023-2024 Ntt Managed Services India Private Limited, The Dcit, Vs. Hyderabad. Telangana. Circle-5(1), Hyderabad. Pin 500 081 Pan Aarcs7517G (Appellant) (Respondent) िनधा"रती "ारा/Assessee By -None- राज" व "ारा/Revenue By : Sri Mathivanan Sa, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02.03.2026 घोषणा की तारीख/Pronouncement: 04.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: Sri Mathivanan SA, Sr. AR
Section 108(8)Section 143(1)Section 80J

remedy available, lies in the machinery provisions of the Act rather seeking legal remedy. Such provisions 16 ITA.No.1165/Hyd./2025 are found in section 119(2)(b) which enables an assessee to approach the Board for seeking relief in such cases. The provisions of section 119(2)(b) are reproduced

Shri. John Kishore, Tamil Nadu vs. Assessing Officer, Madurai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 4090/CHNY/2025[2020-21]Status: DisposedITAT Chennai02 Mar 2026AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 4090/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Shri John Kishore, The Deputy Commissioner No.13, Munsif Court South Vs. Of Income Tax, Street, Sattur, Non-Corporate Circle 2, Virudhunagar – 626 203. Madurai Pan: Aztpj 1241L (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S.P. Chidambaram, Advocate ""यथ" क" ओर से/Respondent By : Shri Aroon Praasad, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 02.03.2026 आदेश/ O R D E R Per George George K: This Appeal Filed By The Assessee Is Directed Against The Addl./Jcit(A)’S, Indore Order Dated 09.10.2025 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Year Is 2020-21. :- 2 -: 2. The Solitary Issue That Is Raised Is Whether The First Appellate Authority (Faa) Had Erred In Law & On Facts In Not Granting Foreign Tax Credit (Ftc) Of Rs.5,73,078/-.

For Appellant: Shri S.P. Chidambaram, AdvocateFor Respondent: Shri Aroon Praasad, Addl.CIT
Section 119(2)(b)Section 139(1)Section 139(5)Section 143(1)Section 154Section 250Section 90

above, it is apparent that unless there is an order condoning the delay in filing Form No. 67 by the PCIT under Section 119(2)(b), such Form No. 67 can't be taken into consideration and the relief u/s. 90/91 cannot be allowed by the Appellate Authority even