ITAT Kolkata Rules on FTC Claim & Form 67 Filing Deadline

Timirbaran Mazumder Vs DCIT (ITAT Kolkata)

ITAT Kolkata order on denial of Foreign Tax Credit (FTC) claimed under Section 90/90A of the Income Tax Act, 1961, due to the delayed filing of Form 67

Question:

whether the filing of Form 67 within the due date prescribed under Section 139(1) is a mandatory requirement or merely directory for the purpose of claiming FTC under the Double Taxation Avoidance Agreement (DTAA).

Brief Facts:

• The assessee, a resident individual, filed his return of income for AY 2018-19 on 29.03.2019 under Secti

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