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ITAT Orders Re-Examination of FTC Denial Due to Form 67 Mistake

Case Law Details

Case Name
John Deere India Pvt. Ltd. Vs DCIT (ITAT Pune)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2023-24
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John Deere India Pvt. Ltd. Vs DCIT (ITAT Pune) FTC Lost Due to Wrong Column in Form 67: ITAT Restores Entire Claim for Re-Verification-Clerical Error Should Not Cost ₹1.03 Cr—Tribunal Sends FTC Matter Back to AO Assessee filed return on 27.11.2023 declaring income of ₹13,84,91,15,667, claiming Foreign Tax Credit (FTC) of ₹8,06,67,574 u/s 90 & ₹2,46,31,826 u/s 91. CPC, while processing u/s 143(1), allowed full FTC u/s 90 but restricted FTC u/s 91 to ₹1,42,39,456, thereby disallowing ₹1,03,92,370 relating to taxes paid in Chile & Spain. Assessee’s filed Form 67 shows that...
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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 5,510

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