Ram Avadhanulu Jonnavithula Vs DCIT (ITAT Bangalore)
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.
Facts- This appeal is filed by the assessee against the ex parte order dated 03.07.2024 of the CIT(Appeals), National Faceless Appeal Centre, Delhi [NFAC], for the AY 2017-18 in not condoning the delay in filing the appeal and dismissing the appeal on the issue of claim of foreign tax credit.
Conclusion- Held that we have gone through the reasons submitted by the assessee before the ld. FAA for delay of 1809 days in filing the appeal and we are of the view that there is reasonable cause for the delay, it is observed that there are sufficient reasons for the delay and following the judgment of the Hon’ble Apex Court in the case of Collector, Land Acquisition Vs. MST. Katiji and Others (1987) 167 ITR 471, delay in filing the appeal before the CIT(Appeals) is condoned. Accordingly, AO directed to allow Foreign Tax Credit after due verification of Form 67.
FULL TEXT OF THE ORDER OF ITAT BANGALORE
