The assessee filed his return of Income on 27.08.2019. After filing the return, assessee received intimation u/s 143(1) of the Act dated 23.03.2021 and found that relief under section 90 of the Act had not been allowed amounting to Rs 73,658/-.
ITAT Bangalore held that delay of 1809 days in filing of an appeal condoned since reasonable cause shown for the delay. Accordingly, appeal allowed and AO directed to allow Foreign Tax Credit after due verification of Form 67.
ITAT Surat held that the delay in filing the appeal before CIT(A) is not deliberate or intentional or due to gross negligence on the part of the assessee. Accordingly, delay of more than 2 years condoned and matter remanded back to CIT(A).
