TaxTMI 
TaxTMI 
2024 (5) TMI 815
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....UDICIAL MEMBER : The instant appeal filed by the assessee is directed against the order dated 15.02.2023 passed by the Commissioner of Income Tax (Appeals), NFAC, Delhi under Section 250 of the Income Tax Act, 1961 (hereinafter referred as to 'the Act') arising out of the assessment order dated 11.01.2021 passed by the CPC, Bengaluru under Section 143(1) of the Act for the Assessment Year (A.Y.) ....
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....Such plea made by the assessee's Counsel has not been controverted by the Learned DR with all his fairness. Needless to mention, that such statement made by the AR also appears to be genuine, which has been brought to our notice even by filing an application dated 02.05.2023. We, therefore, being satisfied with the "reasonable cause" so explained by the Learned AO condone the delay in filing the a....
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....claim FTC late on 06.04.2021. As this particular filing of form 67 was first introduced from A.Y. 2018-19, which, the assessee was not aware of, as claimed by the AR, the same was not filed along with the return of income as a procedural matter. Rectification application thereon though filed, the same was rejected on this technical ground. 4. At the time of hearing of the instant appeal, under th....
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.... Since the Form 67 has been filed, the same could be verified by the Learned AO and to give relief accordingly. He has relied upon the various judgments passed by the different Courts including the Hon'ble Apex Court in the case of Sambhaji and others vs. Gangabai and others reported in (2008) 17 SCC 117, wherein it has been held that procedural law should not ordinarily be construed as mandatory;....