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TMI Blog2023 (11) TMI 700X X X X Extracts X X X X X X X X Extracts X X X X ..... RDER PER DR. MANISH BORAD, ACCOUNTANT MEMBER : The above captioned appeal is directed at the instance of the revenue against the order of the National Faceless Appeal Centre, (hereinafter the "ld. CIT(A)") dt. 19/10/2022, passed u/s 250 of the Income Tax Act, 1961 ("the Act") for the Assessment Year 2020-21. 2. The Registry has pointed out that there is a delay of 2 days in filing the present a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd it should be treated as mandatory. 2. That the appellant craves leave to add, alter, amend, modify, substitute, delete and/or rescind all or any of the grounds of appeal on or before final hearing." 4. At the outset, the ld. Counsel for the assessee submitted that in view of the CBDT Circular No. 17/2019, dtd. 08/08/2019, this appeal of the revenue deserves to be dismissed for low tax effect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he revenue does not deserve to be dismissed on account of low tax effect. 8. So far as the merits of the case are concerned, we find that the assessee was denied the foreign tax credit (FTC) of Rs. 3,66,855/-. The assessee is a salaried employee of Pricewaterhouse Coopers Pvt. Ltd. (PwC India) and was sent on short terms assignment to United States of America (U.S.A.) from 09/09/2018 to 18/03/202 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... whether the assessee is eligible to claim such FTC. 8.1. We notice that this issue had come up for adjudication before us in various other cases wherein also, the decision of other Tribunals have been cited and it has been consistently held that filing of From 67 is merely directory in nature and even if it is filed belatedly, the assessee deserves the FTC. We find support from the decision of th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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