9911796707
TMI Blog2024 (11) TMI 1101X X X X Extracts X X X X X X X X Extracts X X X X ..... xes in India as well as abroad and the tax paid in the foreign country are eligible to be credited towards the total tax payments. Since the factum is not in dispute, delay in filing cannot prejudice the right of the assessee to claim Foreign Tax Credit (FTC). Keeping in view the specificities of the instant case, the Revenue is hereby directed to accord Foreign Tax Credit (FTC) to the assessee an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in filing of Form 67. 2. The Learned CIT (Appeals) erred in holding that the appellant was not entitled to claim relief of Rs. 10,28,529 since he had failed to file form 67 read with Rule 128. 3. The Learned CIT (Appeals) erred in disregarding the submission made during the course of appellate proceedings and further erred in holding that as per Rule 128 prevailed u/s 90 of the Act. 4. The Learned ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... plication filed by the assessee vide rectification order u/s 154 of the Act on 12.09.2023 owing to the delay of filing Form No. 67. 4. Aggrieved by the order of the Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A) who also dismissed the appeal of the assessee on the ground that the assessee has not followed Rule 128 in respect of filing Form No. 67 on or before th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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