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2023 (3) TMI 264
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....o. 5840/Del/2018, the assessee has raised the following grounds of appeal: "1. The Hon'ble CIT(A) has grossly erred in the facts and circumstances of the case and in law in not accepting the contention of the appellant for considering the revised computation of income furnished during assessment proceedings on the premise that the claim cannot be entertained unless made in the return of income (original or revised). 2. The Hon'ble CIT(A) has grossly erred in the facts and circumstances of the case and in law in ignoring the following: (i) the Judicial precedents cited on non-applicability of the decision of Hon'ble Supreme Court in the case of Goetze (India) Ltd, 284 ITR 323 for considering the revised....
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....ed with Bharti Airtel Services Limited (hereinafter referred to as "BASL") and Bharti Airtel Limited (hereinafter referred to as "BAL"). The assessee filed return of income on 31.07.2014 declaring a total taxable income of Rs.3,41,81,660/-. The copy of return of Income along with computation of Income is enclosed herewith as Annexure 3 from Page 13 to 40 of the paper book. The break-up of total taxable income is as under: S. No. Particulars Amount (INR) 1. Salary from BAL 1,04,95,709 2. Salary from BASL 2,26,44,970 3. Income from house property 7,82,173 4. Income from other sources 3,68,813 5. Deduction under chapter (Section 80C of the Act) VIA (1,00,000) 6. Deduction und....
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....ee. Based on the above submission, the Assessing Officer added the income offered amounting to Rs.35,71,641/- and allowed foreign tax credit of Rs. 44,85,507/- (basis the Original computation) completely ignoring the submission filed on September 9, 2016 in this regard, claiming total foreign tax credit of Rs.66,74,802/- revised at this stage. The Assessing Officer has granted only partial foreign tax credit amounting to Rs.44,85,507/- and has omitted to allow the additional relief claimed amounting to Rs.21,85,295/-. The total foreign tax credit due to the appellant amounts to Rs.66,74,802/-,based on the the additional overseas income offered to tax during assessment proceedings. 6. The only tangible ground of Appeal a....