2025 (6) TMI 2115

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.... PER GEORGE GEORGE K, VICE PRESIDENT: This appeal filed at the instance of the assessee is directed against the order of Addl/JCIT-1, Chandigarh dated 17.02.2025 passed under section 250 of the Income Tax Act, 1961 (hereinafter called 'the Act'). The relevant Assessment Year is 2019-20. 2. The solitary issue that is raised is whether the First Appellate Authority is justified in confirming ....

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.... amounting to Rs. 1,45,890/- claimed in the return of income was denied (for the reason of failure to furnish Form 67). On receipt of intimation issued u/s.143(1) of the Act, the assessee filed Form 67 on 10.03.2021 and thereafter on 04.05.2021, the assessee filed rectification application u/s. 154 of the Act. However, on 21.05.2021 the CPC rejected the application filed u/s.154 of the Act. 5. ....

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.... solitary issue for our consideration is whether the assessee is entitled to FTC amounting to Rs. 1,45,891/- on the tax paid for the dividend income earned in USA. The reason for denying the benefit of FTC was that assessee did not file Form 67 within the due date prescribed u/s. 139(1) of the Act. Admittedly, the assessee had filed the return of income within the due date prescribed u/s. 139(1) o....

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....enied since the assessee did not file applicable Form No.67 to claim the said relief. The assessee filed Form No. 67 along with rectification application u/s 154 on 18.07.2022 in respect of her claim. However, CPC again denied the same in an intimation issued u/s 154. Upon further appeal, Ld. CIT(A), relying on the decision of Bangalore Tribunal in the case of Brinda Ramakrishna vs ITO (ITA No. 45....