“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

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

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

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

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

Madhu Khatri, Singapore vs. DCIT Circle 3(3)(1), Bangalore

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

ITA 1032/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Jul 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year :2017-18

For Appellant: Shri. Naman Maloo, CAFor Respondent: Shri. Pradeep S, Addl. CIT(DR)(ITAT), Bangalore

Section 10Section 10(14)Section 143(1)Section 90

confirming the action of Id. AO(CPC) in disallowing the credit of taxes paid outside India while processing the return of income (Foreign Tax Credit, "FTC") under Section 143(1) of the Income Tax Act, 1961. Such rejection is beyond the purview of Section 143(1). The action ... illegal and arbitrary, and against the facts of the case. Relief may please be granted by allowing the foreign tax credit, as its rejection being outside the preview of Section 143(1). Page 2 of 6 2. In the facts and circumstances of the case, the assessee had duly submitted

Pratim Chakraborty, Kolkata vs. ITO, Ward 43(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 437/KOL/2025[2019-20]Status: DisposedITAT Kolkata28 Jul 2025AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz)

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

ADDL/JCIT(A) has erred in confirming the action of the Ld. Assessing Officer, CPC (Ld. AO) of not allowing Foreign Tax Credit ('FTC") of Rs. 3.52,291 allowable as per Section 90 of the Income Tax Act, 1961 ('Act') read with Article 25 of the India-USA Double Taxation Avoidance ... India, income earned by the assessee in and outside India during the AY 2019-20 was offered to tax in India and Foreign Tax Credit (FTC) was claimed as per Article 25 of the India USA DTAA. Such return filed has been processed under section 143(1) of the Income

Semantic Square LLP, Ameenpur vs. Income Tax Officer, Ward-(1), Sangareddy

In the result, appeals ITA

ITA 719/HYD/2025[2022-2023]Status: DisposedITAT Hyderabad25 Jul 2025AY 2022-2023

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Shri CA, Ravi BharadwajFor Respondent: MS. G Saratha, Sr. AR And Shri Gurpreet Singh, Sr. AR

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

return of income for the assessment year 2020-2021 on 31.12.2020. Further, the assessee had filed Form-67 on 10.11.2021 and claimed Foreign Tax Credit [in short “FTC”] of Rs.1,91,137/-. The return of income filed by the assessee has been processed and intimation under section

Semantic Square LLP, Ameenpur vs. Income Tax Officer, Ward-(1), Sangareddy

In the result, appeals ITA

ITA 718/HYD/2025[2021-2022]Status: DisposedITAT Hyderabad25 Jul 2025AY 2021-2022

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Shri CA, Ravi BharadwajFor Respondent: MS. G Saratha, Sr. AR And Shri Gurpreet Singh, Sr. AR

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

Semantic Square LLP, Ammenpur vs. Income Tax Officer, Ward-(1), Sanga Reddy

In the result, appeals ITA

ITA 717/HYD/2025[2020-2021]Status: DisposedITAT Hyderabad25 Jul 2025AY 2020-2021

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Shri CA, Ravi BharadwajFor Respondent: MS. G Saratha, Sr. AR And Shri Gurpreet Singh, Sr. AR

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

Sanmoy Ray, Hooghly vs. Income Tax Officer 24(2), Hoohghly

In the result, appeal filed by the assessee is allowed

ITA 683/KOL/2025[2023-24]Status: DisposedITAT Kolkata24 Jul 2025AY 2023-24

Bench: Us, The Ld. Ar Argued That The Filing Of Form 67 Within The Stipulated Time Was A Directory Provision & Not Mandatory. It Was Averred That The Us-India Dtaa Would Come To The Rescue Of The Assessee In This Regard.

Section 143(1)Section 250Section 90

this case, the assessee filed return of income on 16.07.2023, which was processed u/s 143(1) of the Act and Foreign Tax Credit (FTC) was denied by the AO-CPC. 1.2 Aggrieved with this action, the assessee approached the Addl./JCIT(A) but could not succeed on the ground that ... under: “7. Before proceeding further, we would like to reproduce rule 128 of the Income-tax Rules, 1962 (the Rules) which relates with foreign tax credit as under: "Foreign Tax Credit. 128 (1) An assessee, being a resident shall be allowed credit for the amount of any foreign tax paid

Sanjiv Soshil Mehta, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 5(2), Kautilya Bhavan

In the result, appeal of the assessee is allowed

ITA 2096/MUM/2025[2020-2021]Status: DisposedITAT Mumbai23 Jul 2025AY 2020-2021

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Ble

For Appellant: Revenue byFor Respondent: Income-tax – 1, Mumbai

Section 143(1)Section 143(2)Section 143(3)Section 144BSection 263Section 90

अधिकरण INCOME TAX APPELLATE TRIBUNAL Ι.Τ.Α. No. 2096/Mum/2025 3 for AY 2020-21 alongwith UK Tax return and related working of Foreign Tax Credit claimed in return. On perusal of ITR for AY 2020-21 it was found that, assessee is a Resident and Ordinary Resident of India ... assessee's computation of total income showed that salary from UK offered for taxes in India was Rs 101,92,906/- on which Foreign Tax Credit claimed was Rs 96,29,657/-. 4. The facts as evident from return filed by assessee clearly shows that, assessee offered UK salary

Senthil Kumar Thangavelu, Bangalore vs. DCIT, Circle-3(3)(1), Bangalore

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

ITA 916/BANG/2025[2019-20]Status: DisposedITAT Bangalore22 Jul 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2019-20

For Appellant: Shri Navneeth N. Kini, CAFor Respondent: Shri Subramanian, Jt.CIT(DR)(ITAT), Bengaluru

Section 143(1)Section 90

intimation issued u/s. 143(1) of the Income-tax Act, 1961 Page 2 of 5 [the Act] by the CPC dated 23.3.2021 disallowing Foreign Tax Credit [FTC] of Rs.79,518 was dismissed. 2. The brief facts of the case show that assessee is an individual, employed with Qualcomm India ... assessee filed return of income on 23.9.2019 at a total income of Rs.1,29,31,520. In the return, he claimed Foreign Tax Credit [FTC] of Rs.79,518. This return was processed u/s. 143(1) of the Act on 23.3.2021 wherein the FTC claimed u/s. 90/ 90A of Rs.79

Balasubramanian Saravanan, Chennai vs. ITO, Ncw-17(7), Chennai

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

ITA 1498/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Jul 2025AY 2017-18

Bench: Shri George George Kand Shri S.R. Raghunatha

For Appellant: Shri Abhishek Murali, CAFor Respondent: Shri AR. V. Sreenivasan, CIT

Section 119(2)(b)Section 139(1)Section 143(1)Section 250Section 90

returning an income of Rs.19,00,020/-. The return was processed and intimation was issued u/s.143(1) of the Act on 30.03.2019 wherein Foreign Tax Credit u/s.90/90A of the Act amounting to Rs.2,34,995/- claimed in the return of income was denied. On receipt of intimation issued u/s.143 ... which was not considered by the CPC. 4. Aggrieved by the intimation issued u/s.143(1) of the Act for denying the claim of Foreign Tax Credit, the assessee filed appeal before the First Appellate Authority (FAA). The FAA confirmed the disallowance of FTC stating that the assessee has not filed

Ramachandran Shivan, Coimbatore vs. DCIT, Ncc-2, Coimbatore

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

ITA 2557/CHNY/2024[2018-19]Status: DisposedITAT Chennai17 Jul 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.2557/Chny/2024 िनधा"रण वष"/Assessment Year: 2018-19 Ramachandran Shivan, Vs. The Deputy Commissioner Of A-4, No. 18, Saffron Summers, Dr. Income Tax, Narayanaswamy Street, Red Fields, Non Corporate Circle 2, Coimbatore 641 045. Coimbatore. [Pan:Areps9702L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Banusekar, Advocate ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 02.06.2025 घोषणा की तारीख /Date Of Pronouncement : 17.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 08.08.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) – 16, Chennai For The Assessment Year 2018-19. 2. Ground Nos. 1 & 2 Are General In Nature & Requires No Adjudication.

For Appellant: Shri T. Banusekar, AdvocateFor Respondent: Ms. R. Anita, Addl. CIT

allowed for statistical purposes. 8. Ground No. 11 to 13 raised by the assessee are relating to denial of foreign tax credit. 9. The ld. AR submits that the Assessing Officer denied foreign tax credit and made upward modification in the income of the assessee as taxable salary. He further ... submits that the ld. CIT(A) held that the view of 4 I.T.A. No.2557/Chny/24 the Assessing Officer is correct in denying foreign tax credit for non-filing of Form 67 within the time prescribed. The ld. AR drew our attention to the order of this Tribunal in the case

Yogesh Hanumantrao Joshi, Pune vs. DCIT Circle - 12, Pune

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

ITA 956/PUN/2025[2019-20]Status: DisposedITAT Pune16 Jul 2025AY 2019-20

Bench: Dr.Manish Borad

For Appellant: NoneFor Respondent: Shri Deepak Kumar Kedia

Section 143(1)Section 143(1)(a)Section 250Section 6Section 90

perusal of record, I observe that the only issue raised in the instant appeal is that the assessee has been denied benefit of Foreign Tax Credit of Rs.2,06,116/-. Ld. Departmental Representative stated that ld. CIT(A) has already restored the issue to the file of Assessing Officer

Sumukh Suresh Bhardwaj, Bengaluru vs. Income Tax Officer, Ward-7(2)(1), Bangalore

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

ITA 935/BANG/2025[2019-20]Status: DisposedITAT Bangalore10 Jul 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Shri Veerabasanagouda, CAFor Respondent: Shri Ganesh R Ghale, Advocate for Standing

Section 139(1)Section 143(1)Section 90

year 2019- 20. 2. The only effective issue raised by the assessee is that the learned CIT(A) erred in not allowing the Foreign Tax Credit of Rs.5,15,245/- only. Page 2 of 10 2.1 The facts in brief are that the assessee is a salaried individual and regularly ... Income Tax Rule 1962. Hence, the CPC while processing the return under section 143(1) of the Act disallowed the claim of foreign tax credit in the absence of form 67 vide intimation dated 19-03-2021 and raised the demand of Rs. 6,63,110/- only. The assessee subsequently

Anurag Sure, Hdyerabad vs. ITO (Int Taxn)-2, Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 649/HYD/2025[2022-23]Status: DisposedITAT Hyderabad07 Jul 2025AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, S VenugopalFor Respondent: Shri Pavitran Kumar J, Sr. AR

Section 139Section 139(1)Section 139(4)Section 143(1)

individual, filed his return of income for the A.Y 2022-23 on 07.11.2022 declaring total income of Rs.29,62,280/- and claimed foreign tax credit of Rs.5,70,918/-. The return of 2 ITA.No.649/Hyd./2025 income filed by the assessee has been processed and intimation ... appeal, the learned CIT(A) sustained the additions made by the Assessing Officer towards disallowance of Foreign Tax Credit on the ground that, filing of Form 67 within the due date specified u/s 139(1) of the Act is mandatory and since the assessee has not filed Form 67, therefore

Nanda Kumar Parthasarathy, Chennai vs. ITO, Ncw-15(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 853/CHNY/2025[2020-21]Status: DisposedITAT Chennai07 Jul 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.Y. Sridhar, FCAFor Respondent: Mr. Gautham S. Mukundan

Section 139(1)Section 91

examine the appeal on its merits. 3. The only grievance of the assessee is against the action of the Ld.CIT(A) denying the Foreign Tax Credit (FTC) as claimed by the assessee. 4. The brief facts are that the assessee, an individual, filed his return of income ... considered the rival contention and perused the orders of the lower authorities. Short question in this appeal is whether assessee is entitled to foreign tax credit even when form number 67 required to be filed according to the provisions of rule 128 (9) of the Income Tax Rules

Shri Ramasamy Jayakumar, Kanchipuram vs. DCIT, Non Corp. Circle-17(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 852/CHNY/2025[2020-21]Status: DisposedITAT Chennai07 Jul 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.S.P. ChidambaramFor Respondent: Mr.Gautham S. Mukundan

Section 139(1)Section 139(5)Section 143(1)Section 90

hear the appeal on merits. 3. The only grievance of the assessee is against the action of the Ld.CIT(A) denying the Foreign Tax Credit (FTC) as claimed by the assessee. 4. The brief facts are that the assessee, an individual, claims to be a Resident and Ordinarily Resident ... Income-tax Act, 1961 ("the Act") on 16th December 2020, declaring an income of Rs.58,04,949/- and claiming a Foreign Tax Credit ('FTC') of Nil. Thereafter, the assessee had filed a revised RoI for AY 2020-21 u/s.139(5) of the Act on 31 March 2021, declaring a higher

Sivakarthick Raman, Madurai vs. The Assistant Commissioner of Income Tax, International Taxation, Circle Madurai

In the result, the appeal of the assessee is allowed in terms of our above order

ITA 281/CHNY/2025[2022-23]Status: DisposedITAT Chennai07 Jul 2025AY 2022-23

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:281/Chny/2025 िनधा"रण वष" / Assessment Year: 2022-23 Sivakarthick Raman, The Assistant Commissioner Of 5/200, 2Nd Street, Alagupillai Nagar, Vs. Income Tax, T.Pudukudi, International Taxation Circle, Achampathu, Madurai. Madurai – 625 019. [Pan: Ajnpr-3214-R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. Preeti Goel, Advocate ""थ" की ओर से/Respondent By : Ms. Anitha, Addl. C.I.T. सुनवाई की तारीख/Date Of Hearing : 21.04.2025 घोषणा की तारीख/Date Of Pronouncement : 07.07.2025 आदेश /O R D E R Per S. R. Raghunatha, Am:

For Appellant: Ms. Preeti Goel, AdvocateFor Respondent: Ms. Anitha, Addl. C.I.T

Section 143(3)Section 144C(13)Section 15Section 15(1)(a)Section 234BSection 234DSection 5(2)Section 5(2)(a)Section 9(1)(ii)Section 90

Samy clearly states that the Tribunal had only disallowed the treaty relief on ground that the Assessee was claiming :-14-: ITA. No.:281/Chny/2025 foreign tax credit relief for taxes paid on doubly taxed income, which is applicable in the case of Resident of India, Article 23 allows exemption only ... offered to tax in China. The salary reconciliation statement has been placed by Ld. AR on record. The assessee has not claimed any foreign tax credit in any of the jurisdiction. The China tax has been paid by the foreign entity i.e., M/s Ford Motor (China

Ttec India Customer Solutions Pvt. Ltd., Ahmedabad vs. The Pr.CIT-3, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1026/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad04 Jul 2025AY 2020-21

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2020-21 Ttec India Customer Solutions Pr.Commissioner Of Private Limited, Ttec Ahmedabad Vs. Income Tax-3 Opp: L.J.College Vejalpur Off: Sg Road, Makarba Ahmedabad. Fatewadi Bo, Fatewadi Ahmedabad. Pan : Aaccm 1005A (Applicant) (Responent) : Shri Vishal Kabra, Ar Assessee By : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 03/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 04/07/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Rignesh Das, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 263Section 37(1)Section 80G

computed in accordance with the provisions of the Act and offered to tax in India. It was further submitted that foreign tax credit of Rs.8,02,50,535/- was claimed under Article 24 of the India– Philippines DTAA, for which Form 67 was duly filed on 29.12.2020. The AO, after ... income of Rs.46.54 crore should have been offered to tax in India. iii. That the AO failed to examine the correctness of the foreign tax credit claimed in Form 67 and did not conduct independent verification of foreign income and its computation. 5. Based on these findings, the PCIT concluded

Manoj Madhukar Gajarlawar, Kanchipuram vs. ACIT, Ncc-22(1), Tambaram

In the result, appeal filed by the assessee is allowed

ITA 1030/CHNY/2025[2021-22]Status: DisposedITAT Chennai04 Jul 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.Girish Sonthlia, AdvocateFor Respondent: DR is on leave

Section 119(2)(b)Section 139(1)Section 143(1)Section 90

referred to as ‘AY‘) 2021-22. 2. The only grievance of the assessee is against the action of the Ld.CIT(A) denying the Foreign Tax Credit (FTC) as claimed by the assessee. Manoj Madhukar Gajarlawar :: 2 :: 3. The brief facts are that the assessee, an individual, filed his return ... would always be directory in nature. Respectfully following the same, we direct Ld. CIT(A) to grant impugned Foreign Tax Credit to the assessee after verifying Form No.67. 6. In the result, appeal filed by the assessee is allowed. Order pronounced on the 04th day of July, 2025, in Chennai

Yuraaz Arora, Mumbai vs. Ward 34(1)(1), Mumbai

In the result, grounds of appeal raised by assessee are allowed

ITA 4904/MUM/2024[2019-20]Status: DisposedITAT Mumbai04 Jul 2025AY 2019-20

Bench: SHRI PAWAN SINGH (Judicial Member)

Section 139Section 139(1)Section 154Section 254(1)Section 90

following grounds of appeal: “ 1. The Hon'ble Addl./JCIT(A)-1 Jaipur erred in confirming the action of AO in not allowing Foreign Tax credit of Rs 48,241/- u/s 90 of the Income Tax Act, 1961 (the Act) by holding that Form 67 has not been filed ... Appellant submits that delay in filing Form 67 is procedural in nature and cannot be a reason to deny the Foreign Tax Credit to the Appellant, hence, the Appellant submits that he shall be allowed the FTC as claimed in return of income filed

Praveen Saxena, Lucknow vs. ITO-6(1), Lucknow-New

The appeal of the assessee stands allowed

ITA 202/LKW/2024[2020-21]Status: DisposedITAT Lucknow03 Jul 2025AY 2020-21

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2020-21 Praveen Saxena V. Income Tax Officer 6(1) Flat No.G-01, Tower-J Lucknow - New Shalimar Gallant Vigyanpuri, Mahanagar Lucknow Tan/Pan:Ajpps5818N (Appellant) (Respondent) Appellant By: Shri Samrat Chandra, C.A. Respondent By: Shri Sanjeev Krishna Sharma, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 07.02.2024, Passed By The Ld. Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi For Assessment Year 2020-21. 2.0 The Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Year Under Consideration On 09.01.2021, Declaring A Total Income Of Rs.22,57,120/- & Also Claimed Relief Under Section 90 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) For A Sum Of Rs.3,48,632/- Being Foreign Tax Credit. The Centralized Processing Centre (Cpc) Processed The Return Under Section 143(1) Of The Act & Rejected The Relief Of Rs.3,48,632/- Claimed By The Assessee Under Section 90 Of The

For Appellant: Shri Samrat Chandra, C.AFor Respondent: Shri Sanjeev Krishna Sharma, D.R

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

claimed relief under section 90 of the Income Tax Act, 1961 (hereinafter called “the Act’) for a sum of Rs.3,48,632/- being Foreign Tax Credit. The Centralized Processing Centre (CPC) processed the return under section 143(1) of the Act and rejected the relief of Rs.3,48,632/- claimed ... with permission. 3.0 The Ld. Authorized Representative for the assessee (Ld. A.R.) submitted that the grievance of the assessee was the denial of Foreign Tax Credit as claimed by the assessee due to the reason of delay in filing Form 67 which was filed on 18.08.2022. It was submitted that