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The ITAT Delhi held that denial of foreign tax credit u/s 90...
Foreign tax credit u/s 90 even if form 67 filed belatedly, is allowable subject to verification by the AO. Assessee entitled to claim relief as per DTAA.
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The ITAT Delhi held that denial of foreign tax credit u/s 90 solely for not filing Form 67 before original tax return u/s 139(1) is incorrect. Assessee can claim credit per DTAA even if Form 67 is filed with revised return. CIT (A) erred in not considering the claim before AO. Following Goetze (India) Ltd. case, claim is admitted for justice. Issue remitted to AO for consideration based on documents submitted. Assessee's appeal allowed for statistical purposes.
The ITAT Delhi held that denial of foreign tax credit u/s 90 solely for not filing Form 67 before original tax return u/s 139(1) is incorrect. Assessee can claim credit per DTAA even if Form 67 is filed with revised return. CIT (A) erred in not considering the claim before AO. Following Goetze (India) Ltd. case, claim is admitted for justice. Issue remitted to AO for consideration based on documents submitted. Assessee's appeal allowed for statistical purposes.
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