2024 (5) TMI 29

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....ational Faceless Appeal Centre [in short the "NFAC"] Delhi's Din and Order No. ITBA/NFAC/S/250/2023-24/ 1050339607(1), dated 03.01.2024, involving proceedings u/s. 154 of the Income Tax Act, 1961 (in short "the Act"). Heard both the parties. Case file perused. 2. The assessee pleads the following substantive grounds in the instant appeal : "1. The learned CIT(A) erred both on facts and in law ....

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....the fact as well as the law that, the issue involved is not debatable and there is only one view possible on the issue, even if it involves long drawn process of reasoning." 3. Suffice to say, the assessee's sole substantive grievance herein challenges both the learned lower authorities action disallowing him Foreign Tax Credit "FTC" for the reason that he had filed the corresponding Form 67 bela....