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Delay Condoned for FTC Claim: Pursuing Rectification is Valid Cause
Case Law Details
- Case Name
- Xerago E-Biz Services Pvt. Ltd. Vs ITO (ITAT Chennai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2021-22
- Courts
- All ITAT, ITAT Chennai
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Xerago E-Biz Services Pvt. Ltd. Vs ITO (ITAT Chennai)
In this case, the assessee’s appeal was dismissed by the CIT(A) as time-barred with a delay of 615 days. The issue involved denial of Foreign Tax Credit (FTC) of ₹26.17 lakh.
Before the ITAT, the assessee demonstrated a detailed chronology showing that:
Immediately after intimation u/s 143(1), it filed rectification applications.
It continuously pursued the remedy u/s 154 before CPC and AO.
The final rejection of rectification and confirmation of demand became known only upon receipt of demand notices in October 2024, ...





