Foreign Tax Credit Allowed Despite Delayed Filing of Form 67: ITAT Delhi

Parag Gupta Vs ITO (ITAT Delhi) The appeal arose from the order of the JCIT(A) affirming the CPC’s intimation under Section 143(1) for AY 2021-22, whereby foreign tax credit (FTC) of ₹13,91,287 claimed under Sections 90/90A was denied on the ground that Form No. 67 had not been filed within the due date prescribed under Section 139(1). The assessee, a resident salaried employee of Amazon Seller Services Pvt. Ltd., had earned salary income in both India and the USA, offered his global income to tax in India, paid tax in the USA, and claimed FTC in respect of those taxes. Although the re...