2024 (4) TMI 1118

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.... INTURI RAMA RAO, AM: This is an appeal filed by the assessee directed against the order of National Faceless Appeal Centre, Delhi (NFAC) dated 25.01.2024 for the assessment year 2020-21. 2. Briefly, the facts of the case are that the appellant is an individual (Resident) deriving income under the head "salary" from M/s. John Deere India Private Limited. During the year under consideration, ....

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....t is in appeal before us in the present appeal. 5. It is submitted that filing of Form No.67 within the due date for filing of the return of income is not mandatory, but it is mere a directory under the provisions of the Income Tax Rules, 1962. He further submitted that as on date of processing the return of income, a Form No.67 was uploaded, which the CPC, Bangalore had failed to take into con....

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....esent case, Form No.67 was not filed within the due date for filing of the return of income under the provisions of section 139(1), but Form No.67 was filed on 26.03.2021. The CPC, Bangalore had processed the return of income on 06.08.2021 which means that Form No.67 was very much available with the CPC, Bangalore. Therefore, the CPC, Bangalore cannot deny the claim for credit for foreign tax paid....