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TMI Blog2022 (2) TMI 103X X X X Extracts X X X X X X X X Extracts X X X X ..... sideration. Tribunal accepted the assessee's contention in the proceedings arising out of the order passed u/s. 143(3), the instant appeal on the very same issue, flowing from the order passed u/s.154, has virtually become infructuous. Respectfully following the order passed by the Tribunal for the same year allowing Foreign Tax credit in respect of interest income offered during the year unde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e impugned order. - ITA Nos. 968 and 969/PUN/2018 - - - Dated:- 20-1-2022 - R. S. Syal , Vice President And S. S. Viswanethra Ravi , Member ( J ) For the Appellant : Mohit Jain For the Respondents : Nikhil Pathak ORDER Per R.S. Syal, VP These two appeals by the Revenue relating to the assessment years 2011-12 and 2012-13 emanate from the common order dated 28.02.2018 pass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r TDS. The AO, in the order passed u/s. 143(3), did not allow credit for the TDS. Thereafter, the assessee filed rectification application u/s. 154, INTER ALIA, requiring the AO to grant credit for such TDS. The AO in the instant proceedings arising, out of application u/s. 154, did not accept the contention of the assessee. The ld. CIT(A), however, allowed the assessee's claim. Aggrieved ther ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arising out of the order passed u/s. 143(3), the instant appeal on the very same issue, flowing from the order passed u/s. 154, has virtually become infructuous. Respectfully following the order passed by the Tribunal for the same year allowing Foreign Tax credit in respect of interest income offered during the year under consideration, we uphold the impugned order on this score. 5. The facts ..... X X X X Extracts X X X X X X X X Extracts X X X X
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