ITAT Chennai Allows Foreign Tax Credit Despite Late submission of Form 67

ITO Vs Smt. Chengam Durga (ITAT Chennai)

Income Tax Appellate Tribunal (ITAT) Chennai heard an appeal by the Revenue against an order by the Commissioner of Income Tax (Appeals) [CIT(A)], which allowed Foreign Tax Credit (FTC) to Smt. Chengam Durga despite a delayed filing of Form 67. The Revenue argued that the CIT(A) erred in treating Form 67 as directory rather than mandatory and relied on decisions of ITAT Bangalore and Jaipur. The dispute arose when the Centralized Processing Center (CPC) denied FTC during return processing under Section 143(1), as Form 67 was not filed with t

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