Shri Nobuhiro Watabe vs. The Deputy Commissioner of Income Tax
Parties Involved
Facts Summary
The assessee, Shri Nobuhiro Watabe, a foreign citizen, filed his return of income for the assessment year 2018-19 on 28.08.2018. He filed Form 67 belatedly on 04.09.2018 to claim Foreign Tax Credit (FTC). The intimation issued under section 143(1) of the Income Tax Act denied the FTC amounting to Rs.15,73,721/-. Aggrieved by this, the assessee appealed to the First Appellate Authority (FAA), which confirmed the disallowance of FTC, stating it lacked the power to condone the delay in filing Form 67. The assessee then filed the present appeal before the Tribunal, submitting that the issue was in his favor based on previous judgments.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the belated filing of Form 67 disentitles the assessee from claiming Foreign Tax Credit.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
7 precedents cited in this judgement.
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