2023 (7) TMI 1442

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.... This is an appeal filed by the Revenue directed against the order of the National Faceless Appeal Centre ['NFAC'] dated 16.01.2023 for the assessment year 2021-22. 2. Briefly, the facts of the case are that the respondent-assessee is a resident and also a tax resident of USA filed the Return of Income for the assessment year 2021-22 on 21.10.2021 by claiming foreign tax credit of Rs. 4,32....

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....ereafter, the respondent-assessee had filed another Form No. 67 on 28.03.2022 by correcting the wrong assessment mentioned in the Form No. 67 and requested for rectification of the intimation. But, the CPC had not allowed the said rectification. Against the said intimation, an appeal was filed before the NFAC with the delay. The NFAC condoned the delay and proceeded to dispose of the ma....

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....n filing the appeal. (ii) The CPC had not granted the credit for foreign tax credit for the reasons that wrong assessment year was mentioned in Form No. 67 had been adverted to the reasons were not available in the intimation u/s 143(1) of the Act, but contains a wrong assessment year. 6. Therefore, the NFAC ought not to have granted the relief without calling for a remand report from the ....