2026 (7) TMI 411

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.... income for the A.Y. 2022-23 on 28.07.2022 disclosing a total income of Rs. 3,87,770/-. The assessee was on assignment to United States Of America(U.S.A) in the F.Y.2021-2022 and paid taxes. The assessee has filed the revised return of income u/sec139(5) of the Act on 01.11.2022 including salary income from U.S.A and claimed Foreign Tax Credit(FTC) of Rs. 1,76,456/- under the provisions of section 90/91 of the Act as per the India-USA Double Taxation Avoidance Agreement (DTAA). Subsequently, return of income was processed u/sec 143(1) of the Act accepting the income as per the return of income tax filed by the assessee but no relief was granted u/sec 90 of the Act in respect of Foreign Tax Credit (FTC) and raised a demand of Rs. 2,57,480/- ....

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....ry. Whereas the Coordinate Bench of this Hon'ble Tribunal in ITA No. 76/PUN/2025 in the case of Sandeep Damodar Jadhav Vs I T O Ward-3, satara A.Y.2021-22 dated 21.03.2025 has considered the facts, law on filing of Form 67 and observed at Para 3 to 7 of the Order as under: "3. In the instant appeal, assessee has raised as many as six grounds and perusal of the same indicate that the soel grievance of the assessee is that the Ld. CIT(A) erred in not granting the FTC of Rs. 2,31,471/-merely on the grounds that From No. 67 which was required to be filed in support of the claim of FTC was filed beyond the due date of filing the return of income 4.On going through the written submissions filed by the assessee, we notice that it....