2023 (5) TMI 151

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....U/s. 143(1) of the Income Tax Act, 1961 [the Act] dated 24/12/2021 for the AY 2020-21. 2. Brief facts of the case are that the assessee is an having residential status of Resident and Ordinarily Resident, filed his return of income on 31/3/2021 admitting a total income of Rs. 83,77,420/-for the AY 2020-21 and also claimed a foreign tax credit of Rs. 17,55,145/-. The return of income was summarily processed by CPC which denied the foreign tax credit as claimed by the assessee. Aggrieved by the order of the CPC, the assessee filed an appeal before the Ld. CIT(A), Hyderabad. The Ld. CIT (A) considering the provisions of Rule 128(1) of the Income Tax Rules, 1962, dismissed the appeal of the assessee stating that the assessee has not filed a st....

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....rdinance, 2020 (the Ordinance) on 31/3/2020 which was extended vide Notification No. 88/2020/F, No. 370142/35/2020-TPL upto 31/1/2021. The Ld. AR further submitted that as per Clause-(b) of Sl.No.4 of the Press Release (supra) the due date for furnishing of Income Tax returns for AY 2020-21 covered u/s. 44AB of the Act has been extended to 15/2/2021. Accordingly, the assessee has filed the return of income on 15/2/2021 and filed the statement of Form-67 on 31/3/2021. The Ld. AR therefore pleaded that the assessee has complied with the extended due date and hence the claim of foreign tax credit shall be allowed to the assessee. Per contra, the Ld. DR relied on the order of the Jurisdictional Tribunal in ITA No. 269/Viz/2021 (AY: 2018-19), d....