Foreign Tax Credit under DTAA cannot be denied for Delay in filing Form 67
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Foreign Tax Credit under DTAA cannot be denied for Delay in filing Form 67

Case Law Details

Case Name
Rohan Hattangadi Vs CIT (A) (ITAT Mumbai)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2020-21
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Rohan Hattangadi Vs CIT (A) (ITAT Mumbai) From Rule 128, it is evident that the assessee has to file Form 67 on or before the due date of furnishing the return of income as per section 139(1) of the Act, which the statement specifies as mandatory and not directory as per the word ‘shall’ used in the said provisions. It is evident that the assessee has filed Form 67 belatedly after the due date for filing of return u/s. 139(1) and, hence, the lower authority have rejected the claim of the assessee. Though the decision cited by the ld. Departmental Representative (ld. DR for short) in Murali...
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