2025 (7) TMI 1834

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....uthami Manivasagam, JCIT ORDER PER ABY T. VARKEY, JM: This is an appeal preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter referred to as "the Ld.CIT(A)"), Delhi, dated 17.02.2025 for the Assessment Year (hereinafter referred to as "AY") 2018-19. 2. The only grievance of the assessee is against the action of the Ld.CIT(A) denyin....

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.... Form 67, as required under Rule 128 of the Income Tax Rules, 1962, on or before the due date of filing the ITR u/s.139(1) of the Act. According to the assessee, the said Form was later filed voluntarily on 18.06.2020 on coming to know about the omission. During the scrutiny assessment, the AO asked the assessee 'as to why' the FTC claim should not be denied since Form 67 was not filed within the ....

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....t is not disputed that the assessee had filed belatedly Form 67 on 18.06.2020 and brought to the notice of the AO that it has filed Form 67 on 18.06.2020 during the course of assessment proceedings. However, the AO passed the assessment order on 10.01.2021 denying the claim only on the ground that the assessee didn't file Form 67 before the due date of filing of the ITR u/s.139(1) of the Act, whic....