Denial of Foreign Tax Credit (FTC) claimed u/s. 90 - there was ...

Case Laws Income Tax

March 11, 2024

Denial of Foreign Tax Credit (FTC) claimed u/s. 90 - there was delay in furnishing Form 67 - The Tribunal referred to a similar case where Form 67 was not filed before the processing of the return under section 143(1) of the Act but was filed subsequently. In that case, the Tribunal directed the Assessing Officer (AO) to give credit for FTC after due verification of Form 67. - The Tribunal concluded that the denial of FTC for the delay in filing Form 67 was not justified. Therefore, it directed the AO to give credit for FTC after due verification of Form 67.

View Source

← Previous Next →

Denial of Foreign Tax Credit (FTC) claimed u/s. 90 - there was ...

Case Laws Income Tax

March 11, 2024

You may also like:

Section 90 of the Income Tax Act allows relief from double taxation by granting foreign tax credits (FTCs) on foreign income taxed in both India and the other country....

The High Court, following the judgment in G.M. Knitting Industries (P.) Ltd., held that filing a foreign tax credit claim u/r 128 is directory and not mandatory. The...

Foreign Tax Credit u/s. 90 - Assessee did not file Form 67 at the time of filing of her return of income - Referring to established case law, the Tribunal affirmed that...

Relief u/s. 90 - Foreign Tax Credit (FTC) - In the instant case, the delay in filing of the FTC certificate in Form-67 was explained to be due to non receipt of the tax...

Denial of foreign tax credit u/s 90/90A due to delay in filing Form no.67 - Mere delay in filing Form No. 67 as per the provisions of Rule 128(9), as they stood during...

Denial of foreign tax credit u/s 90/90A due to delay in filing Form no.67 - mere delay in filing Form No. 67 as per the provisions of Rule 128(9), as they stood during...

Relief u/s 90 - foreign tax credit - disallowance of FTC in case of delay in filing Form No. 67 - the assessee is eligible for foreign tax credit, as she has filed form...

Foreign Tax Credit (FTC) u/s 90 r.w. Article 25 India US Treaty (DTAA) - Claim denied as Assessee could not file Form 67 online along with return - The Tribunal accepted...

The ITAT Delhi held that denial of Foreign Tax Credit (FTC) claim due to late filing of Form 67 after the due date of filing Income Tax Return (ITR) was not justified....

Foreign tax credit u/s 90/90A - delay in filing Form no.67 - mere delay in filing Form No. 67 as per the provisions of Rule 128(9), as it stood during the year under...

Claim of foreign tax credit (FTC) u/s 90 - Rule 128 of the Rules cannot override the provisions of DTAA and impose an additional condition that credit will not be given...

Foreign Tax Credit u/s 90/90A - - The Tribunal found that while the DTAA does not prescribe a filing requirement for FTC, the Income Tax Rules (Rule 128) do mandate the...

The Appellate Tribunal addressed the disallowance of benefit u/s 90/90A for foreign tax paid in Bhutan due to Form No. 67 not filed within time frame. Relying on legal...

The ITAT Delhi held that denial of foreign tax credit u/s 90 solely for not filing Form 67 before original tax return u/s 139(1) is incorrect. Assessee can claim credit...

Denial of foreign tax credit u/s 91 - delay in filing Form no.67 - Mere delay in filing Form No. 67 as per the provisions of Rule 128(9), as they stood during the year...

Quick Updates: