CPC denied assessee’s claim of Foreign Tax Credit (FTC) alleging that Form No. 67 was not filed within prescribed time. CIT(A) confirmed the action of CPC on the ground that Form No. 67 was not filed before the time limit specified under section 139(1) and filing of Form No. 67 is mandatory to claim the benefit of FTC. Assessee contended that filing of Form No. 67 is a directory requirement but not mandatory. Form No. 67 was not filed by assessee within the due date of filing return under section 139(1), but the same was filed before processing of return by CPC. Therefore, CPC was not justified in denying the assessee’s claim of FTC merely because Form No. 67 was not filed within the due date specified for filing return under section 139(1), as it is merely directory in nature.(AY. 2019-20) [ITA No. 2491/PUN/2024 dated 21/01/2025]
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