Disallowance of Foreign Tax Credit due to delay in filing of Form No. 67 not tenable in law

Brinda Rama Krishna Vs ITO (ITAT Bangalore) Facts-The Assessee claimed FTC of Rs. 4,73,779/- u/s. 90 of the Act read with Article 24 of India Australia tax treaty (“DTAA”) in a revised return of income filed on 31.8.2018. however, the Assessee had not filed the Form 67 before filing the ROI. On realising the same, the Assessee filed Form 67 in support of claim of foreign tax credit on 18.04.2020. The revised return of income was processed by Centralized Processing Centre (CPC) electronically and intimation u/s 143(1) of the Act on 28.05.2020 was passed disallowing the claim of FTC....