2024 (9) TMI 866

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....the instance of assessee is directed against the order of Ld. Commissioner of Income Tax (Appeals)-Addl/JCIT(A)-2, Mumbai (hereinafter referred to as Ld. CIT(A)] dated 29.01.2024 for AY 2019-20. 2. The following grounds of appeal raised by the assessee are as under: i) That on facts and circumstances of the case and in law, the Ld. CIT(A) has erred in upholding the disallowance of foreign tax c....

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.... even though the notice of hearing has been sent by RPAD on 19.08.2024. On observing that small issue has been raised against the denial of Foreign Tax Credit of Rs. 11,42,039/- we decide to adjudicate the same with the assistance of Ld. D.R and available records. 4. The sole grievance of the assessee is that the Ld. CIT(A) erred in upholding the disallowance of foreign tax credit (in short FTC) ....

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....for the period from 02.04.2018 to 31.12.2018. The said income has duly been offered to tax in the income tax return. However, a sum of Rs. 11,42,039/- was deducted at source by the employer in USA. The assessee furnished Form 67 claiming FTC of Rs. 11,42,039/- . The FTC claimed by the assessee has been denied on account of delay in filing Form 67. 7. We find that this issue has been raised before....