BHUPENDRA BORA,GHAZIABAD vs. DCIT, DEHRADUN

In the result, the appeal is allowed

Bench: Shri M. Balaganesh & Shri Satbeer Singh Godara(Through Video Conferencing) Bhupendra Bora, Vs. Dcit, Flat No. S4, Plot No. 618A, Circle-1(1)(1), Sector-1, Vaishali, Dehradun Ghaziabad (Appellant) (Respondent) Pan: Ajkpb5486A Assessee By : None Revenue By: Shri A. S. Rana, Sr. Dr Date Of Hearing 17/03/2025 Date Of Pronouncement 02/04/2025

193 ITD 840 (Bang Trib). The relevant operative portion of the said order is reproduced below:- “3. There is no dispute that the Assessee is entitled to claim FTC. Rule 128 of the Income-tax Rules, 1962 (Rules) provides for giving FTC and reads thus : 'Foreign Tax Credit. 128. (1) An assessee, being a resident shall be allowed a credit

M/S THDC INDIA LIMITED, RISHIKESH,RISHIKESH vs. PCIT, DEHRADUN, DEHRADUN

In the result, appeal of the assessee is partly allowed

disallowance u/s 80 IA, the same\nis taxed without any real income. Ld. AR thus, requests that deduction\nu/s 80IA of the Act on these items of income deserves to be allowed.\n11. On the other hand, Ld.Sr.DR vehemently supported the orders of\nthe lower authorities and submits that Ld.CIT(A) has passed a reasoned\norder wherein items on which