← All Phrases

“foreign tax credit”

International TaxSection 90 / Rule 128Section 90 / Rule 128571 judgments

The decision most relied on for foreign tax credit is Chandra Kishore Jha v. Mahavir Prasad (8 SCC 266), cited in 163 judgments on BharatTax.

Leading authorities on foreign tax credit

Chandra Kishore Jha v. Mahavir Prasad
8 SCC 266 · 1999 · Supreme Court
163
citing judgments

If a statute or law prescribes that a thing must be done in a particular manner, then it must be done in that manner alone and in no other way. This principle mandates strict adherence to statutory procedures.

Wipro Ltd. v. DCIT
382 ITR 179 · 2016 · High Court
122
citing judgments

Foreign Tax Credit (FTC) is allowable even if no tax is paid in India on the corresponding income due to deductions under sections 10A or 10AA, or losses in other units. The scope of income eligible for deduction under Section 10AA includes interest on deposits and realized gains on forward contracts.

Ms. Brinda Ramakrishna v. ITO
135 Taxmann.com 358 · 2022 · ITAT
109
citing judgments

The filing of Form 67 for claiming Foreign Tax Credit (FTC) is a directory requirement, not mandatory. Rule 128(9) does not provide for disallowance of FTC due to delay in filing this form. Double Taxation Avoidance Agreements (DTAAs) override domestic law.

CIT v. ACE Multitaxes Systems (P.) Ltd.
317 ITR 207 · 2009 · High Court
107
citing judgments

For claiming relief under Chapter VI-A deductions like Section 80IB or 80IA, the audit report in Form 10CCB is not mandatory to be filed with the return of income, but can be submitted before the assessment is completed.

Sambhaji and Others v. Gangabai and Others
17 SCC 117 · 2008 · Supreme Court
87
citing judgments

Procedural law serves as an aid to justice, not an obstruction, and should not ordinarily be construed as mandatory; it is subservient to substantive justice.

42 Hertz Software India (P.) Ltd. v. ACIT
139 Taxmann.com 448 · 2022 · ITAT
62
citing judgments

The claim for Foreign Tax Credit cannot be denied solely due to a delay in filing Form-67, as the requirement for filing Form-67 under Rule 128(9) is considered directory and not mandatory. The provisions of a Double Taxation Avoidance Agreement (DTAA) prevail over the Income-tax Act, 1961.

Duraiswamy Kumaraswamy v. PCIT
460 ITR 615 · 2024 · High Court
50
citing judgments

An assessee's claim for Foreign Tax Credit (FTC) cannot be rejected merely because Form 67 was filed after the due date under section 139(1), provided it is filed before the completion of assessment proceedings.

Sonakshi Sinha v. CIT
142 Taxmann.com 414 · 2022 · ITAT
37
citing judgments

The requirement to file Form 67 by the due date for claiming foreign tax credit is directory, not mandatory, if filed before the completion of assessment proceedings.

Judgments citing foreign tax credit

Kalyanasundaram Ramasubramanyam, Chennai vs. Income Tax Officer, Chennai

The appeal of the assessee stands allowed for statistical purposes

ITA 3322/CHNY/2024[2021-22]Status: DisposedITAT Chennai25 Mar 2025AY 2021-22

Bench: SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI MANU KUMAR GIRI (Judicial Member)

For Appellant: Shri Ranganathan Ramesh, C.AFor Respondent: Ms. V. Aswathy, JCIT
Section 139(1)Section 143(1)Section 90

arising out of the order of the Commissioner of Income The captioned appeal filed by the assesseeinvolves an issue i.e., allowance of foreign tax credit (FTC). The appeal for AY 2021-22 arises out of an order passed by Learned Addl. /Joint Commissioner of Income Tax (Appeals)-8, Mumbai ... matter of an intimation issued by CPC, Bengaluru u/s 143(1) on 05-07-2022 denying Foreign Tax Credit of Rs.1,48,670/- as claimed by the assessee u/s 90. The same was denied for want of filing of requisite Form 67 along with return of income. 2. It emerges

Subramanian Swaminathan, Chennai vs. Assistant Commissioner of Income Tax, Chennai

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

ITA 3276/CHNY/2024[2021-22]Status: DisposedITAT Chennai25 Mar 2025AY 2021-22

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.3276/Chny/2024 (िनधा"रणवष" / Assessment Year: 2021-2022) Subramanian Swaminathan, Vs. The Assistant Commissioner Of Flat C, New No.4, Old No.24, Income Tax, Chandrashekar Apartments, Non Corporate Circle 4(1) 4Th Street, Kodambakkam, Chennai 600 006. Chennai 600 024. [Pan: Bkeps 4414H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Logesh, Advocate ""यथ" क" ओर से /Respondent By : Ms. M. Aswathy, Jcit सुनवाई क" तार"ख/Date Of Hearing : 24.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.03.2025 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri Logesh, AdvocateFor Respondent: Ms. M. Aswathy, JCIT
Section 282Section 90

return of income on 28.12.2021 for the AY 2021-22 declaring income of Rs.55,73,110/- and claimed the tax relief i.e; Foreign Tax Credit (‘FTC’ in short) u/s 90/90A of the Act of Rs.1,38,138/-. However, the CPC while processing the return denied relief of FTC and raised ... assessee is in further appeal before us. 3. Before us, the ld.counsel submitted that the ld.CIT(A) erred in denying the claim of Foreign Tax Credit (‘FTC’) u/s 90/90A of the Act of Rs.1,38,138/-, without properly serving the notice for hearings. 4. The ld. DR relied upon

Sandeep Damodar Jadhav, Mumbai vs. I.T.O Wrd-3, Satara

In the result, the appeal of the assessee is allowed

ITA 76/PUN/2025[2021-22]Status: DisposedITAT Pune21 Mar 2025AY 2021-22

Bench: Dr.Manish Borad & Shri S.S.Viswanethra Raviआयकर अपील सं. / Ita No.76/Pun/2025 Assessment Year : 2021-22

For Appellant: NoneFor Respondent: Shri Manoj Tripathi
Section 143(1)(a)Section 250

perusal of the same indicate that the sole grievance of the assessee is that the ld.CIT(A) erred in not granting the Foreign Tax Credit (FTC) of Rs.2,31,471/- merely on the ground that Form No.67 which was required to be filed in support of the claim

DCIT, Circle 4(2), New Delhi vs. Consulting Engineering Services (India) Private Limited, New Delhi

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

ITA 4091/DEL/2024[2009-10]Status: DisposedITAT Delhi21 Mar 2025AY 2009-10

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Dcit, Vs. Consulting Engineering Circle-4(2), Services (India) Pvt. Ltd, 2Nd Floor, Plot No. 184, Platinum New Delhi Tower, Udyog Vihar, Phase-1, Gurgaon (Appellant) (Respondent) Pan: Aaacc5110G Assessee By : Ms. Ananya Kapoor, Adv Shri Tarun Chanana, Adv Shri Shivam Yadav, Adv Revenue By: Shri Sanjay Kumar Bharati, Cit Dr Date Of Hearing 16/01/2025 Date Of Pronouncement 21/03/2025

For Appellant: Ms. Ananya Kapoor, AdvFor Respondent: Shri Sanjay Kumar Bharati, CIT DR
Section 127Section 142Section 143(3)Section 250

erred in law and the facts of the case in not adjudicating the issue of non-grant of foreign tax credit of Rs. 45,91,188/- under section 91 of the Act and remanding the same back to the Ld. AO for examination. Consulting Engineering Services (India

Anoosha Paruchuri, Hyderabad vs. Income Tax Officer, Ward-2, Karimnagar

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

ITA 145/HYD/2025[2021-22]Status: DisposedITAT Hyderabad20 Mar 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: A. Sharren, AdvocateFor Respondent: : Shri Suresh Babu, SR-DR
Section 139(1)Section 143(1)Section 90

facts and circumstances of the case, the Ld. First Appellate Authority is justified in confirming the action of the CPC in denying the Foreign Tax Credit (“FTC”) claimed by the assessee u/s.90 of the Income Tax Act, 1961 ('the Act'), for the reason that the assessee filed Form no.67 beyond ... discussed above as well as the decisions of this Tribunal, Hon'ble High Court and Hon'ble Supreme Court, we hold that the Foreign Tax Credit cannot be denied merely because there is a delay in filing Form-67. Accordingly, we direct the Assessing Officer to allow the Foreign Tax

Timirbaran Mazumder, Kolkata vs. D.C.I.T./A.C.I.T., Circle 2(1), International Taxation, Kolkata

The appeal are allowed

ITA 1905/KOL/2024[2018-19]Status: DisposedITAT Kolkata20 Mar 2025AY 2018-19

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 139(1)Section 143(1)Section 143(1)(a)Section 143(3)Section 250Section 90

appeal: “1. That the order of the Ld. CIT(A) is erroneous both on facts and in law in not allowing the Foreign Tax credit claimed under section 90/90A to the extent of Rs.14,35,797/-. 2. The Ld. CIT (A) while observing so, totally ignored the settled principle that ... have appreciated that it is not mandatory to file Form 67 before filing return of income under section 139(1) to claim Foreign tax credit as Rule 128(9) of the Rules does not provide for disallowance of FTC in case of delay in filing Form No.67 and that filing

Kantar Gdc India Private Limited, Hyderabad vs. DCIT., Circle - 2(1), Hyderabad

The appeal of the assessee is partly allowed for statistical purposes

ITA 804/HYD/2024[2020-21]Status: DisposedITAT Hyderabad19 Mar 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ajit Kumar Jain, C.AFor Respondent: Ms. M. Narmada, CIT-DR
Section 115JSection 143(3)Section 156

With regard to ground no.27, the Ld. AR submitted that while passing the final assessment order, the Ld. AO failed to grant foreign tax credit, despite the fact that the necessary details and documents were available before the Ld. AO. 25. Per contra, the Ld. DR fairly submitted that ... assessee is eligible for foreign tax credit as per law, the Ld. AO may verify and allow the claim. 26. We have heard the rival contentions and also gone through the record in the light of the submissions made by either side. In the facts and circumstances of the case

Kantar Gdc India Private Limited, Hyderabad vs. ACIT., Circle - 2(1), Hyderabad

The appeal of the assessee is partly allowed for statistical purposes

ITA 274/HYD/2024[2017-18]Status: DisposedITAT Hyderabad19 Mar 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ajit Kumar Jain, C.AFor Respondent: Ms. M. Narmada, CIT-DR
Section 115JSection 143(3)Section 156

With regard to ground no.27, the Ld. AR submitted that while passing the final assessment order, the Ld. AO failed to grant foreign tax credit, despite the fact that the necessary details and documents were available before the Ld. AO. 25. Per contra, the Ld. DR fairly submitted that ... assessee is eligible for foreign tax credit as per law, the Ld. AO may verify and allow the claim. 26. We have heard the rival contentions and also gone through the record in the light of the submissions made by either side. In the facts and circumstances of the case

Anand Mahabal Shetty, Mumbai vs. Assistant Director of Income Tax, CPC., Bangalore

In the result, the appeal of the appellant is allowed

ITA 593/MUM/2025[2019-20]Status: DisposedITAT Mumbai18 Mar 2025AY 2019-20

Bench: Shri Om Prakash Kant (Am) & Smt. Kavitha Rajagopal (Jm) Anand Mahabal Shetty Adit, Cpc, C/402, Chavandai Chs Bangalore/Acit Opposite Rajpark, Parsik Vs. Qureshi Mansion Nagar, Kalwa, Thane Gokhale Road Mumbai-400 060. Thane-400 602. Pan : Aopps4358Q Appellant Respondent

For Appellant: Shri Ram Krishn KediaFor Respondent: None
Section 119(2)(b)Section 139(1)Section 234BSection 234CSection 90

passed by the learned Commissioner of Income Tax (Appeals), Gwalior [in short CIT(A)] for assessment year 2019-20 in relation to foreign tax credit amounting to Rs. 35,77,264/- denied by the Assessing Officer, Central Processing Centre (CPC) in terms of section 90 of the Income Tax ... short Act). 2. Grounds raised by the appellant are reproduced as under :- “Denial of foreign tax credit 1. erred in confirming the action of AO in denying the foreign tax credit claimed of INR 35,77,264 in the tax return under article 23(2) of the India- China double

Ajit Deepak Gupte, Bangalore vs. ACIT, Circle-3(3)(1), Bangalore

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

ITA 110/BANG/2025[2019-20]Status: DisposedITAT Bangalore12 Mar 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Navaneeth Kini, CAFor Respondent: Smt. Neha Sahay, JCIT
Section 90

sole issue raised by the assessee pertains to the learned CIT(A)’s decision not to grant the benefit of foreign tax credit amounting to ₹1,04,088, despite acknowledging that the assessee is entitled to such credit. 7. The Centralized Processing Center (CPC) denied the foreign tax credit claimed ... belatedly—beyond the due date for filing the income tax return. 8. On appeal, the learned CIT(A) acknowledged that the benefit of foreign tax credit could not be denied merely because Form 67 was filed belatedly. In support of this, the ld. CIT(A) referred to a series

Ajit Deepak Gupte, Bangalore vs. ACIT, Circle-3(3)(1), Bengaluru

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

ITA 109/BANG/2025[2018-19]Status: DisposedITAT Bangalore12 Mar 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Navaneeth Kini, CAFor Respondent: Smt. Neha Sahay, JCIT
Section 90

sole issue raised by the assessee pertains to the learned CIT(A)’s decision not to grant the benefit of foreign tax credit amounting to ₹1,04,088, despite acknowledging that the assessee is entitled to such credit. 7. The Centralized Processing Center (CPC) denied the foreign tax credit claimed ... belatedly—beyond the due date for filing the income tax return. 8. On appeal, the learned CIT(A) acknowledged that the benefit of foreign tax credit could not be denied merely because Form 67 was filed belatedly. In support of this, the ld. CIT(A) referred to a series

ITO Ward 39 (2) vs. Kimti Lal Jain

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

ITA 4091/DEL/2006[1998-1999]Status: DisposedITAT Delhi12 Mar 2025AY 1998-1999

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Dcit, Vs. Consulting Engineering Circle-4(2), Services (India) Pvt. Ltd, 2Nd Floor, Plot No. 184, Platinum New Delhi Tower, Udyog Vihar, Phase-1, Gurgaon (Appellant) (Respondent) Pan: Aaacc5110G Assessee By : Ms. Ananya Kapoor, Adv Shri Tarun Chanana, Adv Shri Shivam Yadav, Adv Revenue By: Shri Sanjay Kumar Bharati, Cit Dr Date Of Hearing 16/01/2025 Date Of Pronouncement 21/03/2025

For Appellant: Ms. Ananya Kapoor, AdvFor Respondent: Shri Sanjay Kumar Bharati, CIT DR
Section 127Section 142Section 143(3)Section 250

erred in law and the facts of the case in not adjudicating the issue of non-grant of foreign tax credit of Rs. 45,91,188/- under section 91 of the Act and remanding the same back to the Ld. AO for examination. Consulting Engineering Services (India

Srikar Perala, Hyderabad vs. Income Tax Officer, Ward-4(1), Hyderabad

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

ITA 108/HYD/2025[2021-22]Status: DisposedITAT Hyderabad11 Mar 2025AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.108/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2021-22) Shri Srikar Perala Vs. Income Tax Officer Hyderabad Ward 4 (1) Pan:Bkepp2494N Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Shashank Dundu, Advocate राज" व "ारा/Revenue By:: Smt. Vishnu Priya, Dr सुनवाई की तारीख/Date Of Hearing: 06/03/2025 घोषणा की तारीख/Pronouncement: 11/03/2025 आदेश/Order

For Appellant: Shri Shashank Dundu, AdvocateFor Respondent: : Smt. Vishnu Priya, DR
Section 6Section 90

credit u/s 90 of the I.T. Act, 1961. The assessee filed a revised computation before the learned CIT (A) for claiming the foreign tax credit. The learned CIT (A) did not accept this contention of the assessee and also denied the claim of foreign tax credit for want of filing ... status as resident, cannot be a Page 4 of 11 ITA 108 of 2025 Srikar Perala reason for denying the claim of foreign tax credit. Thus, the learned AR has submitted that the actual status of the assessee is NRI and therefore, the requirement of filing of Form

Suresh Kumar Vobbilisetty, Hyderabad vs. Income Tax Officer, International Taxation-2, Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1204/HYD/2024[2021-2022]Status: DisposedITAT Hyderabad07 Mar 2025AY 2021-2022

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1204/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2021-22) Shri Suresh Kumar Vs. Income Tax Officer Vobbilisetty, (International Taxation)-2 Hyderabad Hyderabad Pan:Acgpv5441G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca K Hemalatha राज" व "ारा/Revenue By:: Shri Kumar Aditya, Dr सुनवाई की तारीख/Date Of Hearing: 15/01/2025 घोषणा की तारीख/Pronouncement: 07/03/2025 आदेश/Order

For Appellant: CA K HemalathaFor Respondent: : Shri Kumar Aditya, DR
Section 139(1)Section 143(1)Section 91

Suresh Kumar Vobbilisetty appellate authority is justified in confirming the action of CPC in denying the Foreign Tax Credit claimed by the assessee u/s 91 of the I.T. Act, 1961 for the reason that the assessee filed Form-67 beyond the due date of filing the return of income ... learned AR of the assessee has submitted that the Assessing Officer has denied the Foreign Tax Credit only for the reason that the assessee filed the statement in Form 67 belatedly and not within the due date specified for furnishing the return of income

Michael J Ponnambalam, Tirunelveli vs. ITO, Ward-1, Tirunelveli

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 1/CHNY/2025[2021-22]Status: HeardITAT Chennai07 Mar 2025AY 2021-22

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.3340/Chny/2024 & आयकर अपील सं./Ita No.01/Chny/2025 िनधा:रण वष: /Assessment Years: 2020-21 & 2021-22 Michael J Ponnambalam, The Income Tax Officer, 7-40, Sannathi Street, Vs. Ward-1, Vadakangulam S.O., Tirunelveli. Tirunelveli – 627 116. [Pan: Hbjpp 5981C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Girish Kumar, AdvocateFor Respondent: Dr. M.D.Vijay Kumar, JCIT
Section 139Section 139(1)Section 143(1)

u/s.139(8A) of the Act along with Form-67 . The assessee has claimed foreign tax credit of Rs. 1,80,009/- for A.Y 2020-21 and Rs 1,94,582/- for A.Y 2021-22, but the same was denied in the intimation ... income u/s. 139(8A) of the Act along with Form-67 and therefore, the Form 67 in support of the claim for foreign tax credit was available at the time of processing of the return. The Ld. AR argued that filling of Form-67 before the prescribed due date

Michael J Ponnambalam, Tirunelveli vs. ITO, Ward-1, Tirunelveli

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 3340/CHNY/2024[3340]Status: HeardITAT Chennai07 Mar 2025

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.3340/Chny/2024 & आयकर अपील सं./Ita No.01/Chny/2025 िनधा:रण वष: /Assessment Years: 2020-21 & 2021-22 Michael J Ponnambalam, The Income Tax Officer, 7-40, Sannathi Street, Vs. Ward-1, Vadakangulam S.O., Tirunelveli. Tirunelveli – 627 116. [Pan: Hbjpp 5981C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Girish Kumar, AdvocateFor Respondent: Dr. M.D.Vijay Kumar, JCIT
Section 139Section 139(1)Section 143(1)

u/s.139(8A) of the Act along with Form-67 . The assessee has claimed foreign tax credit of Rs. 1,80,009/- for A.Y 2020-21 and Rs 1,94,582/- for A.Y 2021-22, but the same was denied in the intimation ... income u/s. 139(8A) of the Act along with Form-67 and therefore, the Form 67 in support of the claim for foreign tax credit was available at the time of processing of the return. The Ld. AR argued that filling of Form-67 before the prescribed due date

Sivakumar Chiluvuri, Telangana vs. ADIT (Int Taxn)-1, Hyderabad

In the result appeal of the assessee is allowed

ITA 1367/HYD/2024[2018-19]Status: DisposedITAT Hyderabad06 Mar 2025AY 2018-19

Bench: Shri Manjunatha G & Shri K. Narasimha Chary

For Appellant: CA Balaji VenkatsubramaniamFor Respondent: Dr. Sachin Kumar, Sr AR
Section 139(1)Section 143(1)

assessee has filed revised return of 2 ITA.No.1367/Hyd./2024 income on 31.03.2019 declaring total income of Rs.1,81,12,866/- and claimed Foreign Tax Credit [in short “FTC”] at Rs.39,16,468/- by filing Form No.67 along with return of income. The return of income filed by the assessee

Madan Kumar Sivinigari, Bangalore vs. Income Tax Officer, Ward-5(3)(5), Bangalore

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

ITA 2606/BANG/2024[2020-21]Status: DisposedITAT Bangalore05 Mar 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Navneet N Kini, CAFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Section 139(1)Section 143(1)Section 90

only issue raised by the assessee is that the learned CIT(A) erred in not allowing the claim of foreign tax credit. Page 2 of 9 2.1 The necessary facts are that the assessee is an individual and employed with the company, namely Tech Mahindra Ltd. The assessee during ... while processing the return as per the provision of section 143(1) of the Act disallowed the claim of the assessee for foreign tax credit as Form-67 prescribed under rule 128 of the Income Tax Rules was not filed on or before the expiry date to file return

Shah Rukh Khan, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result, the appeal by the assessee is allowed

ITA 6312/MUM/2024[A. Y. 2012-13 ]Status: DisposedITAT Mumbai04 Mar 2025

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalshah Rukh Khan, 44, Mannat, Bj Road, Bandstand, Bandra, Mumbai - 400050 Pan: Aahpk3293L ……………. Appellant V/S Dcit, Central Circle – 4(2) Kautilya Bhavan, Bandra Kurla Complex, Bandra East, ……………. Respondent Mumbai - 400050 Maharashtra

For Appellant: Shri Aditya AjgaonkarFor Respondent: Ms. Kavitha Kaushik, Sr. DR
Section 148Section 250

appellant has to be assessed from the facts of each case. In the instant case, it was about undue availment of foreign tax credit. The AO had a prima-facie view that excessive relief had been claimed by the appellant and that the appellant had not fully and truly disclosed

Suhail Amin Nathani, Mumbai vs. ACIT Circle 16(3), Mumbai

In the result, the appeal is allowed

ITA 6952/MUM/2024[2020-21]Status: DisposedITAT Mumbai27 Feb 2025AY 2020-21

Bench: Shri Saktijit Dey, Vp & Shri Narendra Kumar Billaiya, Am Suhail Amin Nathani Asst. Cit 801, 8Th Floor, Prabhu Kutir, Aaykar Bhavan, R. No. 446, Vs. 15, Altamount Road, Mumbai-400 026 M. K. Road, Mumbai-400 020 Pan/Gir No. Acapn 0531 D (Appellant) : (Respondent) Appellant By : Shri Gautam Thacker Respondent By : Shri Bhangepatil Pusharaj Ramesh Date Of Hearing : 27.02.2025 Date Of Pronouncement : 27.02.2025

For Appellant: Shri Gautam ThackerFor Respondent: Shri Bhangepatil Pusharaj Ramesh
Section 143(1)

Chennai, pertaining to the assessment year (A.Y.) 2020-21. 2. The sole grievance of the assessee in the present appeal concerns disallowance of Foreign Tax Credit (FTC) due to non furnishing of Form No. 67 within the prescribed time limit. 3. Briefly the facts are, in the return of income