2024 (7) TMI 1092

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....r : Mr.V.Vikram for M/s.Subbaraya Aiyar Padmanabhan and Ramamani For the Respondents : Mr.V.Mahalingam, Senior Standing Counsel ORDER An order under Section 154 of the Income Tax Act, 1961 (the Income Tax Act) dated 27.05.2024 is challenged in this writ petition. 2. In respect of assessment year 2022-2023, the petitioner filed the original return of income on 29.11.2022. Thereafter, the petiti....

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....ose circumstances, a rectification petition dated 09.11.2023 was filed. Since such rectification petition was rejected by once again denying the Foreign Tax Credit, the present writ petition was filed. 3. Learned counsel for the petitioner invited my attention to the company tax return filed in Australia. With reference thereto, he pointed out that the tax liability was about Australian dollars 2....

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....r.V.Mahalingam, learned senior standing counsel, accepts notice for the respondents. He submits that the matter may be remanded for reconsideration with regard to the Foreign Tax Credit. 5. On examining the company tax return and the activity statements, it appears prima facie that the petitioner has remitted taxes through the Australian branch. It is clear that Foreign Tax Credit in respect ther....