Foreign Tax Credit Cannot Be Denied Solely Due to Belated Form 67: ITAT Kolkata

Neeta Makkar Vs DCIT (ITAT Kolkata) The ITAT Kolkata allowed the assessee’s appeal and held that the denial of foreign tax credit (FTC) of ₹8,81,398 solely because Form No. 67 was filed after the due date was not sustainable. The assessee had filed the return of income declaring total income of ₹83,88,210, and while the assessment accepted the returned income, the Assessing Officer denied the FTC claimed under Section 90 of the Income-tax Act. The Commissioner (Appeals) upheld the denial on the ground that Form No. 67 had been filed after the due date for filing the return. The Tribu...