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    <title>2023 (10) TMI 621 - ITAT DELHI</title>
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    <description>The appeal was allowed by the Tribunal, overturning the denial of Foreign Tax Credit (FTC) for the assessment year 2019-20. The Tribunal held that the delay in filing Form 67 along with the revised return under section 139(5) was justified due to factors beyond the assessee&#039;s control. It was emphasized that Rule 128(9) does not mandate the disallowance of FTC for delayed filing of Form 67, especially considering recent amendments extending the filing deadline. The Assessing Officer was directed to assess the claim for FTC based on the accepted Form 67 and related documents, ensuring the assessee&#039;s right to be heard.</description>
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      <title>2023 (10) TMI 621 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=444398</link>
      <description>The appeal was allowed by the Tribunal, overturning the denial of Foreign Tax Credit (FTC) for the assessment year 2019-20. The Tribunal held that the delay in filing Form 67 along with the revised return under section 139(5) was justified due to factors beyond the assessee&#039;s control. It was emphasized that Rule 128(9) does not mandate the disallowance of FTC for delayed filing of Form 67, especially considering recent amendments extending the filing deadline. The Assessing Officer was directed to assess the claim for FTC based on the accepted Form 67 and related documents, ensuring the assessee&#039;s right to be heard.</description>
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