Case Law Details
Isha Mago Vs ADIT (ITAT Delhi)
In the appeal of Isha Mago vs. ADIT (Income Tax Appellate Tribunal, Delhi), the primary issue concerned the disallowance of foreign tax credit (FTC) by the CPC and subsequently upheld by the CIT(A), due to the assessee’s late filing of Form 67 in relation to the assessment year 2018-19. Here’s a comprehensive summary of the case:
Background: The assessee filed an appeal against the order of the CIT(A), National Faceless Appeal Centre (NFAC), Delhi, dated 20th November 2023, which affirmed the CPC’s decision to disallow FTC amounting to Rs. 6,64,166/- on the grounds of late filing of Form 67. The CPC, in its intimation under section 143(1) of the Income-tax Act, 1961, disallowed the claim as Form 67 was filed after the due date for filing the return under section 139(1) of the Act.
Grounds of Appeal:
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