Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The Appellate Tribunal considered the denial of Foreign Tax Credit (FTC) due to late filing of Form 67. The return of income for AY 2021-22 was filed on 13.10.2021, with Form 67 submitted on 25.01.2022 and a rectified return on 04.09.2022. The Tribunal held that Form 67 filing is procedural, not mandatory, and non-compliance does not affect the substantive right to claim. Therefore, the grounds raised by the appellant were allowed.
The Appellate Tribunal considered the denial of Foreign Tax Credit (FTC) due to late filing of Form 67. The return of income for AY 2021-22 was filed on 13.10.2021, with Form 67 submitted on 25.01.2022 and a rectified return on 04.09.2022. The Tribunal held that Form 67 filing is procedural, not mandatory, and non-compliance does not affect the substantive right to claim. Therefore, the grounds raised by the appellant were allowed.
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