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2025 (3) TMI 1164

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..... COUNTANT MEMBER : The captioned appeal at the instance of assessee pertaining the assessment year 2021-22 is directed against the order dated 08.11.2024 framed by Addl/JCIT(A), Jodhpur passed u/s.250 of the Income Tax Act, 1961 (in short 'the Act') which inturn is arising out of the Intimation order dated 05.07.2022 passed u/s.143(1)(a) of the Act. 2. When the appeal was called for, none appeare .....

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..... nsistently held by the Coordinate Benches as well as this Tribunal that filing of Form No.67 is merely directory in nature and not mandatory and therefore even if it is filed belatedly the same should be considered for allowing FTC. Ld. Departmental Representative failed to controvert the submissions by the assessee by placing any other binding precedent. 5. We have heard the ld. Departmental Rep .....

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..... paid the taxes abroad and is duly supported by evidence, then the claim of the assessee needs to be allowed. Similar view was also taken by this Tribunal in the case of Rameshwar Dnyaneshwar Bandewar Vs. ITO in ITA No.2402/PUN/2024 order dated 23.12.2024 and Nandkumar Chandra Vs. ITO in ITA No.2329/PUN/2024, order dated 23.12.2024. 6. Respectfully following the above referred decisions of the Co .....

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