2022 (6) TMI 693
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....Sri Sankar Pandi, Sr. AR ORDER PER S. BALAKRISHNAN, ACCOUNTANT MEMBER : This appeal filed by the assessee against the order of the Ld. CIT(A), NFAC, Delhi vide DIN & Order No. ITBA/NFAC/S/250/2021-22/1036689053(1), dated 01/11/2021 passed U/s. 143(3) r.w.s 250(6) of the Act for the AY 2018-19. 2. Brief facts of the case are that the assessee is a salaried employee, who has filed his return of ....
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....ing of the return U/s. 139(1) of the Act. Aggrieved by the order of the Ld. AO the assessee filed an appeal before the NFAC. The Ld. CIT(A), NFAC confirmed the order of the Ld. AO and dismissed the appeal. Aggrieved by the order of the Ld. CIT(A), NFAC the assessee is in appeal before us. 3. The assessee has raised the following grounds of appeal: "1. The order of the Ld. CIT(A) is contrary to ....
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....of assessment proceedings, under the facts and circumstances of the case. 7. The Appellant craves leave to add, amend and / or alter the stands as the occasion may warrant." 4. The only issue with respect to the grounds raised by the assessee is regarding non-filing of Form 67 and consequential denial of foreign tax credit by invoking the Rule 128(9) of the IT Rules. The Ld. AR submitted that f....
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....rs of the authorities below. Based on the written submissions made by the assessee's representative, we find that the Form 67 was not filed by the tax consultant of the assessee due to oversight and pleaded that mistake may be considered as technical mistake and there was a reasonable cause. We find no merit in the submissions made by the assessee's representative that the above reason mentioned b....