2024 (12) TMI 1624

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....iled by the assessee pertaining to the assessment year 2020-21 is directed against the order dated 18.10.2024 passed [in short "the Act"] by the Addl./JCIT(A)- 6, Prayagraj u/s.250 of the Income Tax Act, 1961 which in turn is arising out of Intimation order passed u/s.143(1) dated 24.12.2021. 2. Briefly, the facts of the case are that the appellant is an individual (Resident) deriving income un....

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....r had confirmed the action of the CPC, Bangalore denying the claim of credit for Foreign Tax paid, as the Form No.67 was filed belatedly, i.e., beyond the due date for filing of the return of income. 4. Now the appellant is in appeal before the Tribunal challenging the order passed by ld. NFAC affirming the action of the CPC. 5. When the matter was called for, none appeared on behalf of the ....

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.... within the due date for filing of the return of income as specified under the provisions of section 139(1) of the Income Tax Act, 1961 ('the Act'). Admittedly, in the present case, Form No.67 was not filed within the due date for filing of the return of income under the provisions of section 139(1), but Form No.67 was filed on 30.03.2021. The CPC, Bangalore had processed the return of income as o....

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.... the case of Samiran Arunkumar Dutta Vs. DCIT - ITA No.1195/PUN/2024 dated 14.08.2024 where also assessee was employed with same employer but Foreign Tax Credit was allowed even when Form No.67 was filed belatedly observing as follows : "7. I heard the ld. Sr. DR and perused the material on record. The issue in the present appeal is that whether or not the CPC, Bangalore is justified in d....