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ITAT allowed taxpayer's appeal regarding Foreign Tax Credit denial under India-Denmark DTAA. While Form 67 was filed after ROI submission deadline under s.139(1), ITAT held that AO's rejection solely on delayed filing was improper. Matter remanded to AO for fresh examination of whether taxes were paid in Denmark on same income taxed in India, and if no relief was claimed in Denmark. AO directed to verify facts and decide FTC eligibility per CBDT circular and applicable precedents, rather than reject purely on procedural grounds. Technical breach in Form 67 filing timeline should not defeat substantive DTAA benefit if double taxation occurred.
ITAT allowed taxpayer's appeal regarding Foreign Tax Credit denial under India-Denmark DTAA. While Form 67 was filed after ROI submission deadline under s.139(1), ITAT held that AO's rejection solely on delayed filing was improper. Matter remanded to AO for fresh examination of whether taxes were paid in Denmark on same income taxed in India, and if no relief was claimed in Denmark. AO directed to verify facts and decide FTC eligibility per CBDT circular and applicable precedents, rather than reject purely on procedural grounds. Technical breach in Form 67 filing timeline should not defeat substantive DTAA benefit if double taxation occurred.
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