ITAT Bangalore Allows Foreign Tax Credit Despite Late Form 67 Filing

Rajesh Venkatesh Helavar Vs DCIT (ITAT Bangalore)

FTC Cannot Be Denied for Late Form 67 – Rule 128 Procedural, Sections 90 & 91 Substantive- ITAT Bangalore

Background

Assessee, an Indian resident individual, filed his return of income for AY 2019-20 & claimed Foreign Tax Credit (FTC) in respect of taxes paid outside India on income offered to tax in India. However, the CPC denied the FTC on the ground that Form 67-mandated under Rule 128-was not filed within the prescribed time.

Assessee’s appeal before the CIT(A) was delayed by about 7 month

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