2025 (12) TMI 856

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....the addition of unexplained foreign investment of Rs. 3,31,42,742/- relying of the ITR without appreciating that the assessee was not able to provide any documentary evidences in respect of the aforesaid foreign investment? 2. Whether on the facts of the case and in law, the Ld. CIT(A) was right in allowing the relief u/s. 90/91 of the Act amounting to Rs. 23,02,920/- without appreciating that the assessee has not filed Form No. 67 before the due date u/s. 139(1) of the Income Tax Act 1961 which is mandatory for claiming Foreign Tax Credit as prescribed in Rule 128 of the Income Tax Rules? 3. Whether on the facts and circumstances of the case and in law, Ld. CIT(A) was justified in allowing the appeal of the assessee witho....

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....espectively. 6. The assessing officer further noticed that the assessee has claimed benefit of Double Taxation Relief u/s. 90/91 of the Act. The Assessing Officer finally passed the assessment order dated 06.12.2019 where he made addition on account of investment in shares of foreign company for an aggregate amount of Rs. 3,31,42,742/- in the name of two minor daughters namely, Nanki Parvinder Singh and Nandini Parvinder Singh u/s. 69 of the Act and he has also not allowed credit for tax paid in Singapore amounting to Rs. 23,02,920/- and also invoked provisions of Section 115BBE. 7. The aggrieved assessee appealed before the CIT(A) who granted relief on both the issue. Now the Revenue is aggrieved and is before us. 8. The ld DR veh....

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....f income filed by him vide item No. 7b of Part B -TTI (Computation of Tax liability on Total Income) and information regarding foreign income and tax relief thereon was also duly given in return vide Schedule FSI (Details of Income from outside India) and Schedule TY (Summary of tax relief claimed for taxes paid outside India) of original as well as revised return. Form 67 was also duly submitted under Acknowledgment No. 342138281221217 dated 22.12.2017 along with copy of return filed in Singapore and tax paid in Singapore. Further, a statement giving details of tax paid in Singapore and tax payable in India on the salary income of Singapore taxable in India and also included in taxable income in the return was also submitted to the AO with....