Sh. Ashok Sethi Vs. ACIT, Circle-70(1), New Delhi

Parties Involved

Facts Summary

The assessee’s appeal for assessment year 2018-19 arises against the Commissioner of Income Tax (Appeals)/Addl. JCIT(A)-2, Chennai’s DIN and order no. ITBA/APL/S/250/2025-26/1078504613(1), dated 15.07.2025, involving proceedings under section 154 of the Income-tax Act, 1961. The assessee’s foreign tax credit claim of Rs.1,28,946/- under section 90 r.w.s. 90A of the Act was denied by the lower authorities for not filing/uploading Form 67 on or before the prescribed due date. The assessee subsequently complied with the Form 67 filing/uploading post facto the due date.…

Legal Issues

• 1. Entitlement to foreign tax credit despite late filing of Form 67.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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