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ITAT Pune allows Foreign Tax Credit: Form 67 filing is procedural, not mandatory

Case Law Details

Case Name
Kasper Pieter Tideman Vs ITO (ITAT Pune)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2021-22
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Kasper Pieter Tideman Vs ITO (ITAT Pune) The case of Kasper Pieter Tideman vs. ITO before the ITAT Pune pertains to the denial of Foreign Tax Credit (FTC) due to the delayed filing of Form 67. The assessee, a resident taxpayer, had declared an income of ₹28,88,780 for AY 2021-22 and claimed FTC of ₹1,48,111 for taxes paid in the USA and the Netherlands. However, the Centralized Processing Centre (CPC), Bengaluru, disallowed the credit in its intimation under Section 143(1) of the Income Tax Act, 1961, on the grounds that Form 67 was filed after the due date prescribed under Rule 128(9) of ...
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