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2024 (9) TMI 1266

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..... as not filed within the due date for filing of the return of income under the provisions of section 139(1), but was filed on 21.04.2022. The CPC, Bangalore had processed the return of income on 22.03.2022 which means that Form No.67 was not available with the CPC, Bangalore. Therefore, the CPC, Bangalore was justified in denying the claim for credit for Foreign Tax paid as because Form No.67 was n .....

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..... offered the salary income for the services rendered in United States of America and claimed Foreign Tax Credit (FTC). The appellant filed the Return of Income for the A.Y.2021-22 on 20.12.2021 disclosing total income of Rs. 15,26,750/- after claiming credit for Foreign Tax paid of Rs. 1,45,082/- u/s. 90 read with Article 25 of India-USA Tax Treaty (DTAA) of the Act. However, the Form No.67 was fi .....

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..... s that CPC, Bangalore was justified in denying the credit for Foreign Tax paid, as the assessee had not filed Form No.67 as per amended provisions of the I. T. Rules. 7. I heard the ld. Sr. DR and perused the material on record. The issue in the present appeal is that whether or not the CPC, Bangalore is justified in denying the credit for Foreign Tax paid for the reason that the Form No.67 was no .....

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