9911796707
TMI Blog2024 (11) TMI 1428X X X X Extracts X X X X X X X X Extracts X X X X ..... overed in assessee's favor by the decision of this Tribunal in the case of ITO vs. Smt. Chengam Durga [2024 (4) TMI 1227 - ITAT CHENNAI] considering the decision of Duraiswamy Kumaraswamy [2023 (11) TMI 1000 - MADRAS HIGH COURT] held that filing of this form in terms of Rule 128 was only directory in nature. The rule is only for the implementation of the provisions of the act and it would always b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion issued by CPC, Bengaluru u/s 143(1) on 10-06-2020 denying Foreign Tax Credit of Rs.9.59 Lacs as claimed by the assessee u/s 90. The same was denied for want of filing of requisite Form 67 along with return of income. 3. It emerges that the assessee filed original return of income on 30- 08-2019 but it did not claim FTC of Rs.9.59 Lacs. The assessee revised return of income on 31-03-2019 and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nly directory in nature. The rule is only for the implementation of the provisions of the act and it would always be directory in nature. Respectfully following the same, we direct Ld. CIT(A) to grant impugned Foreign Tax Credit to the assessee after verifying Form No.67. 5. Since facts as well as issue in AY 2019-20 are pari-materia the same, our adjudication as above shall apply mutatis-mutandi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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