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TMI Blog2024 (9) TMI 866X X X X Extracts X X X X X X X X Extracts X X X X ..... ised before this Tribunal on multiple occasions and it has been consistently held that filing of Form 67 is directory in nature and therefore even if it is belatedly filed but is placed on record before the revenue authorities, that before passing of an order, if the facts are verifiable then the legitimate claim made by the assessee should be allowed. We find support from the decision of this Tri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ld. Commissioner of Income Tax (Appeals)-Addl/JCIT(A)-2, Mumbai (hereinafter referred to as Ld. CIT(A)] dated 29.01.2024 for AY 2019-20. 2. The following grounds of appeal raised by the assessee are as under: i) That on facts and circumstances of the case and in law, the Ld. CIT(A) has erred in upholding the disallowance of foreign tax credit amounting to INR 11,42,039/- and disregarding Form 67 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 024. On observing that small issue has been raised against the denial of Foreign Tax Credit of Rs. 11,42,039/- we decide to adjudicate the same with the assistance of Ld. D.R and available records. 4. The sole grievance of the assessee is that the Ld. CIT(A) erred in upholding the disallowance of foreign tax credit (in short FTC) of Rs. 11,42,039/- and also raised the grounds that CPC did not prov ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been offered to tax in the income tax return. However, a sum of Rs. 11,42,039/- was deducted at source by the employer in USA. The assessee furnished Form 67 claiming FTC of Rs. 11,42,039/- . The FTC claimed by the assessee has been denied on account of delay in filing Form 67. 7. We find that this issue has been raised before this Tribunal on multiple occasions and it has been consistently held ..... X X X X Extracts X X X X X X X X Extracts X X X X
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