9911796707
TMI Blog2023 (5) TMI 151X X X X Extracts X X X X X X X X Extracts X X X X ..... (RELAXATION AND AMENDMENT OF CERTAIN PROVISIONS) ACT, 2020 allows any statement to be filed on or before 31/3/2021. As per Sl.No.4(b) of the Press Release for extension of time limits dated 30/12/2020, the period has been extended for filing the return of income upto 15/2/2021. We therefore find that the assessee has rightly filed the return of income on or before the due date for filing the return of income and also the statement in Form-67 within the extended due date of 31/3/2021. As in the present case the assessee has filed the return of income and the statement in Form-67 within the respective due dates as extended by the Ministry of Finance, Government of India. We are therefore of the considered view that the foreign tax cred ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eved by the order of the Ld. CIT(A), the assessee is in appeal before the Tribunal. 3. At the outset, the Ld. AR argued that the assessee filed its original return of income on 15/2/2021 which is the extended due date allowed by the Central Board of Direct Taxes [CBDT] due to Covid-19. The Ld. AR further submitted that statement in Form-67 was filed on 31/3/2021. The Ld. AR relied on THE TAXATION AND OTHER LAWS (RELAXATION AND AMENDMENT OF CERTAIN PROVISIONS) ACT, 2020 and invited our attention to Clause-3(1)(b) which is stated as below: (b) filing of any appeal, reply or application or furnishing of any report, document, return or statement or such other record, by whatever name called, under the provisions of the specified Act; ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8 of the IT Rules, 1962 specifies shall , the Form-67 ought to have been filed within the due date specified U/s. 139(1) of the Act. Contending the above, the Ld. AR submitted that the assessee has filed his return of income within the extended due date and has filed the statement in Form-67 within the extended due dates and hence the argument of the Ld. DR is not in accordance with the extended provisions applicable to the assessee during the COVID Pandemic. 5. We have heard both the parties and perused the materials available on record as well as the orders of the Ld. Revenue Authorities. Admittedly, the foreign tax credit is claimed by the assessee by filing the statement in Form-67 on 31/3/2021. We find that as argued by the Ld. AR, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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