2025 (11) TMI 1609

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....1. 2. At the outset, learned counsel for the assessee referring to the grounds of appeal fairly accepted that impugned order is an exparte due to non-compliance on the part of the assessee. He further submitted that the sole issue raised in the instant appeal is disallowing Foreign Tax Credit (FTC) on account of delay in furnishing Form 67. Referring to plethora of decisions placed in the legal compilation paper book, he stated that it has been consistently held by this Tribunal that furnishing Form 67 is directory and not mandatory in nature and in the light of the decisions, he prayed that the claim of FTC may please be allowed. 3. On the other hand, ld. Departmental Representative (DR) supported the order of the Ld.CIT(A). 4. We....

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....nishing of Form 67 has come up before this Tribunal on various occasions and though the assessee has referred to as many as 11 decisions, we take note of the recent decision of this Tribunal in the case of Uttamkumar Tukaram Patil vs. ITO in ITA No.2693/PUN/2024, dated 02/05/2025 dealing with the very same issue and has held as follows:- (relevant extract) "7. We have heard the rival contentions and perused the record placed before us. In the instant appeal, Foreign Tax Credit claim of Rs. 8,60,645/- has not been allowed to the assessee on account of delay in filing of Form No.67 which contains the details of FTC. We note that the Intimation u/s. 143(1) was passed on 28.03.2021 denying the claim of FTC made by the assessee and at t....