9911796707
TMI Blog2023 (3) TMI 264X X X X Extracts X X X X X X X X Extracts X X X X ..... following grounds of appeal: "1. The Hon'ble CIT(A) has grossly erred in the facts and circumstances of the case and in law in not accepting the contention of the appellant for considering the revised computation of income furnished during assessment proceedings on the premise that the claim cannot be entertained unless made in the return of income (original or revised). 2. The Hon'ble CIT(A) has grossly erred in the facts and circumstances of the case and in law in ignoring the following: (i) the Judicial precedents cited on non-applicability of the decision of Hon'ble Supreme Court in the case of Goetze (India) Ltd, 284 ITR 323 for considering the revised computation during assessment proceedings; (ii) The order suffer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... inafter referred to as "BAL"). The assessee filed return of income on 31.07.2014 declaring a total taxable income of Rs.3,41,81,660/-. The copy of return of Income along with computation of Income is enclosed herewith as Annexure 3 from Page 13 to 40 of the paper book. The break-up of total taxable income is as under: S. No. Particulars Amount (INR) 1. Salary from BAL 1,04,95,709 2. Salary from BASL 2,26,44,970 3. Income from house property 7,82,173 4. Income from other sources 3,68,813 5. Deduction under chapter (Section 80C of the Act) VIA (1,00,000) 6. Deduction under chapter (Section 80TTA of the Act) VIA (10,000) Total taxable income (as per return of 3,41,81,660 The total tax payable as per th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Original computation) completely ignoring the submission filed on September 9, 2016 in this regard, claiming total foreign tax credit of Rs.66,74,802/- revised at this stage. The Assessing Officer has granted only partial foreign tax credit amounting to Rs.44,85,507/- and has omitted to allow the additional relief claimed amounting to Rs.21,85,295/-. The total foreign tax credit due to the appellant amounts to Rs.66,74,802/-,based on the the additional overseas income offered to tax during assessment proceedings. 6. The only tangible ground of Appeal arising in the present Appeal is as under: 1. The learned Assessing Officer has erred in providing the relief claimed under Section 90 of the Act read with Article 25 of the Double Tax Av ..... X X X X Extracts X X X X X X X X Extracts X X X X
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