DTAA Overrides Section 90: FTC Credit Allowed Despite Delay in Form 67 submission

Debanjan Chatterjee Vs Deputy Director of Income Tax (ITAT Kolkata) ITAT Kolkata Ruling on Foreign Tax Credit: Debanjan Chatterjee vs. Deputy Director of Income Tax: The Income Tax Appellate Tribunal (ITAT) Kolkata ruled in favor of Debanjan Chatterjee, setting aside the order of the Commissioner of Income Tax (Appeals) [CIT(A)] and directing the Assessing Officer (AO) to grant Foreign Tax Credit (FTC) under Section 90 of the Income Tax Act. Chatterjee, a non-resident working in the United Kingdom, filed his income tax return belatedly on February 19, 2022, for Assessment Year (AY) 2021-22. Th...