2024 (9) TMI 280

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....EER SINGH GODA RA, JM: This assessee's appeal for assessment year 2021-22 arises against the National Faceless Appeal Centre [in short the "NFAC"] Delhi's Din and Order No. ITBA/NFAC/S/250/2023- 24/1058890068(1), dated 19.12.2023, in proceedings u/s 154 and section 143(1) of the Income Tax Act, 1961 (in short "the Act"). Heard both the parties at length. Case file perused. 2. The assessee....

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....ls ) erred in not considering the decisions of judicial authorities on the similar issue which were cited and explained by the appellant in the appellate proceedings. The appellant prays before Your Honour to kindly direct the Ld AO to allow the tax credit of tax withheld in USA of Rs. 8,61,822/-. 3. The appellant craves leave to add, alter, delete, and substitute any or all grou....