Foreign Tax Credit can’t be denied for late filing of Form 67

Mahua Bagchi Vs ACIT (ITAT Kolkata) Introduction: Mahua Bagchi Vs ACIT (ITAT Kolkata) is a landmark decision that emphasizes the importance of substance over form in tax administration. The case centers on the denial of Foreign Tax Credit (FTC) due to the technicality of late filing of Form 67 under section 139(1) of the Income Tax Act, 1961. The ruling by ITAT Kolkata holds significant implications for taxpayers working abroad, especially in the context of procedural compliance. Analysis Background & Facts: The assessee, an employee of Cognizant Technology Solutions, claimed FTC of Rs. 1...