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2024 (2) TMI 838 - AT - Income TaxForeign Tax Credit u/s 90 - FTC denied as assessee has filed the From No. 67 beyond the due date u/sec 139(1) - mandatory v/s directory obligation - HELD THAT:- As there is no amendment on these aspects in the Section 90 of the Act and the rules cannot override the Act and therefore the filing of Form. No. 67 is not mandatory but it is directory. Accordingly, we restore the disputed issue for limited purpose to the file of the assessing officer to grant Foreign Tax Credit after verification and in accordance with the law - Appeal filed by the assessee is allowed for statistical purposes.
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