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2024 (5) TMI 538 - ITAT NAGPURForeign Tax Credit u/s. 90/91 - statutory requirement prescribed under Rule 128(9) of I T Rules, 1962 for filing of Form 67 before due date of filing of return for claiming FTC - directory of mandatory obligations - Claim denied as assessee belatedly filed the corresponding Form- 67 under Rule 128 of I.T. Rules, 1963 - HELD THAT:- As in similar factual backdrop that case law in light of Duraiswamy Kumaraswamy [2023 (11) TMI 1000 - MADRAS HIGH COURT] has already held the foregoing Rule 128 of I.T. Rules is directory only than mandatory in nature. This is indeed coupled with the fact that assessee had duly filed her Form-67 on 28.12.2021 well before sec. 154 order in question dated 10.03.2022. Faced with this situation, we hardly see any merit in the Revenue’s instant sole substantive grievance.
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