India-UK DTAA: Assessing Officer Directed to Allow FTC After Overlooking Timely Filed Form 67 and Income Return.

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....Foreign Tax Credit (FTC) under Article 24(2) of the India-UK DTAA read with Section 90 - As the assessee has filed original return of income before the due date of filing of the return and form number 67 was also filed prior to the due date of filing of the return, the learned AO Central processing centre as well as the learned CIT – A has grossly erred in holding that assessee has not filed return of income and form number 67 before the due date of filing of the return. These are on record but lower authorities have ignored it for the reasons best known to them. - AO directed to allow Foreign Tax Credit (FTC) - AT....