9911796707
TMI Blog2024 (9) TMI 280X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal for assessment year 2021-22 arises against the National Faceless Appeal Centre [in short the "NFAC"] Delhi's Din and Order No. ITBA/NFAC/S/250/2023- 24/1058890068(1), dated 19.12.2023, in proceedings u/s 154 and section 143(1) of the Income Tax Act, 1961 (in short "the Act"). Heard both the parties at length. Case file perused. 2. The assessee pleads the following impugned grounds in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... orities on the similar issue which were cited and explained by the appellant in the appellate proceedings. The appellant prays before Your Honour to kindly direct the Ld AO to allow the tax credit of tax withheld in USA of Rs. 8,61,822/-. 3. The appellant craves leave to add, alter, delete, and substitute any or all grounds of appeal at the time of hearing." 3. Suffice to say, the sole and su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tive could hardly dispute the fact that the assessee had filed its Form 67 on record in section 154 rectification proceedings. That being the case, we accept the assessee's argument in principle and leave it open for the assessing authority/CPC to factual verify the same as per law. 5. This assessee's appeal is allowed for statistical purposes in above terms. Order pronounced on this 30th day of ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
