Foreign Tax Credit Cannot Be Denied for Delayed Form 67 Filing: ITAT Mumbai

Harshit Satish Gupta Vs DCIT (ITAT Mumbai) Case Summary: The case arose from the denial of Foreign Tax Credit (FTC) amounting to Rs. 2,76,317 claimed by the assessee for taxes paid in Germany for AY 2019-20. The assessee, an individual employed with Tata Consultancy Services Ltd., was deputed to TCS Germany Ltd., where he earned salary income that was subjected to tax in Germany. The foreign salary was duly offered to tax in India as part of his global income, and the assessee claimed FTC under Section 90 of the Income Tax Act, 1961 read with Article 23 of the India-Germany Double Taxation Avo...