SAUMITRA KUMAR, LUCKNOW,UTTAR PRADESH vs. DCIT CIRCLE 12, PUNE, MAHARASHTRA
In the result, the appeal filed by the assessee is allowed
ITA 1520/PUN/2025[2021-22]Status: DisposedITAT Pune14 Aug 2025AY 2021-22
Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1520/Pun/2025 िनधा"रण वष" / Assessment Year : 2021-22 Saumitra Kumar, Vs. Dcit, Circle-12, Pune. Hig 111, Sector E, Aliganj, Lucknow- 226024. Pan : Bcmpk7370J Appellant Respondent Assessee By : Shri Naman Maloo (Virtual) Revenue By : Shri Amit Bobde Date Of Hearing : 23.07.2025 Date Of Pronouncement 14.08.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.04.2025 Passed By Ld. Addl./Jcit(A), Indore [‘Ld. Cit(A)’] For The Assessment Year 2021-22. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. In The Facts & Circumstances Of The Case, Ld. Cit(A) Has Erred In, Confirming The Action Of Ld. 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 Of The Ld. Cit(A) Is Illegal & Arbitrary & Against The Facts Of The Case. Relief May Please
For Appellant: Shri Naman Maloo (Virtual)For Respondent: Shri Amit Bobde
Section 139Section 139(1)Section 143(1)Section 90Section 91
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 90/90A cannot be allowed by the Appellate Authority even if other conditions are fulfilled.
In view of the above, the appellant is not eligible for relief under section 90/90A