TMI Blog2024 (5) TMI 29X X X X Extracts X X X X X X X X Extracts X X X X ..... al or mandatory default - HELD THAT:- Revenue would hardly dispute the clinching fact that the assessee had indeed submitted the Form 67 before the CPC s processing dated 09.01.2023 i.e. on 05.02.2021. This being the clinching fact herein, it is of the considered opinion that both the learned lower authorities could not have rejected the assessee s impugned Foreign Tax Credit claim for the above s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , involving proceedings u/s. 154 of the Income Tax Act, 1961 (in short the Act ). Heard both the parties. Case file perused. 2. The assessee pleads the following substantive grounds in the instant appeal : 1. The learned CIT(A) erred both on facts and in law in not allowing the valid claim of relief u/s. 90 of the Act of Rs. 2,21,741/- of the taxes paid by the assessee outside India merely on the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g drawn process of reasoning. 3. Suffice to say, the assessee s sole substantive grievance herein challenges both the learned lower authorities action disallowing him Foreign Tax Credit FTC for the reason that he had filed the corresponding Form 67 belatedly than within the due date of filing return of income u/s. 139(1) of the Act. The Revenue would hardly dispute the clinching fact that the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X
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