2023 (4) TMI 933

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....RDER This is an appeal by the assessee against the order dated 17.11.2022 of NFAC, Delhi, relating to Assessment Year 2019-20. 2. The assessee is an individual. The assessee filed return of income for Assessment Year 2019-20 on 29.08.2019. In the return, the assessee claimed foreign tax credit in respect of a sum of Rs.3,30,000/-. During the previous year, the assessee earned income in USA a....

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.... the return of income mentioned under section 139(1) of the Act but before the intimation under section 143(1) of the Act dated 23.03.2021. The CIT(A) confirmed the order of the AO on the same reasoning given by the AO for refusing to give credit for foreign taxes paid. 3. Aggrieved by the order of the NFAC, assessee has preferred the present appeal before the Tribunal. It was undisputed by the....

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.... not be given if Form 67 is not filed on or before the due date of filing the return of income as prescribed under section 139(1) of the Act. The Tribunal also took the view that even Rule 128 of the Rules does not provide that if Form 67 is not filed within the stipulated time, relief under section 90 of the Act would be denied. The Tribunal also held that filing of Form No.67 is only a procedura....