9911796707
TMI Blog2024 (9) TMI 1565X X X X Extracts X X X X X X X X Extracts X X X X ..... e view taken in AKSHAY RANGROJI UMALE [ 2024 (2) TMI 159 - ITAT PUNE] Consequently, relying upon the crudit pronouncements of the Co ordinate Bench of the Tribunal, we hold that the assessee is entitled to foreign tax credit irrespective of belated furnishing of Form no.67. Accordingly, all the grounds raised by the assessee are allowed. - Shri V. Durga Rao, Judicial Member And Shri K.M. Roy, Accountant, Member For the Assessee : Shri Sachin Jaiswal For the Revenue : Shri Abhay Y. Marathe ORDER PER K.M. ROY, A.M. The present appeal has been filed by the assessee challenging the impugned order dated 07/06/2024, passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, [ learned CIT(A) ], for the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed Form no.67, to claim foreign tax credit under section 90 of the Act amounting to ₹ 6,99,334, (i.e., 14% of the tax paid outside India). Subsequently, intimation under section 143(1) of the Income Tax Act, 1961 ( the Act ) received from Central Processing Centre, Bengaluru, wherein a demand of ₹ 26,54,950, was raised, the details of which are as under: i) Granting short credit of TDS of ₹ 14,93,947, as against full credit of ₹ 16,86,557, pertaining to salary income of ₹ 31,73,253, which was duly reflected in Form no.26AS; and ii) Denial of credit of foreign tax credit of ₹ 6,99,334, on the contention that Form no.67, was not filed on or before the due date of furnishing the return of income under sectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... v/s DCIT, ITA no.1428/Pun./2023, A.Y. 2019 20, order dated 01/02/2024; ii) DCIT v/s Shri Prabha Nageshwar, ITA no.85/Nag./2023, A.Y. 2020 21, order dated 09/05/2024 iii) Brinda Rama Krishna v/s ITO, ITA no.454/Bang./2021, A.Y. 2018 19, order dated 17/11/2021; iv) M/s. 42 Hertz Software India Pvt. Ltd. v/s ACIT, ITA no.29/Bang./2021 A.Y. 2017 18, order dated 07/03/2022; v) Vinodkumar Lakshmipathi v/s CIT(A), ITA no.680/Bang./2022, A.Y. 2018 19, order dated 06/09/2022; vi) Sonakshi Sinhav/s CIT(A), ITA no.1704/Mum./2022, A.Y. 2018 19, order dated 20/09/2022; and vii) Ritesh Kumar Garg v/s ITO, ITA no.261/Jp./2022, A.Y. 2020 21, order dated 15/09/2022. 7. The learned Departmental Representative supported the order of the authorities below. 8. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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