FTC Denial for mere delayed form 67 submission not justified: ITAT Pune

JCIT (OSD) Vs Raj Surendra Mohan Hajela (ITAT Pune) The case of JCIT (OSD) vs. Raj Surendra Mohan Hajela before ITAT Pune concerns the denial of Foreign Tax Credit (FTC) due to a delay in filing Form 67. The assessee, a tax resident of both India and the USA, claimed FTC of ₹4.32 crores in his tax return for AY 2021-22. While Form 67 was initially filed within the prescribed time, an inadvertent error led to the mention of the wrong assessment year. A corrected form was subsequently submitted after the extended due date, but the Centralized Processing Centre (CPC) denied the claim, citing no...