Foreign Tax Credit cannot be denied at processing stage solely for delayed Form 67 filing where substantive claim is supported.

Foreign Tax Credit could not be denied at the processing stage merely because Form 67 was filed after the due date under section 139(1) where the return and Form 67 were filed on the same date and the record supported the claim. The Tribunal treated the delay as insufficient to defeat the substantive entitlement to credit and held that the adjustment under section 143(1) was unjustified on these facts. The assessee was therefore entitled to verification and grant of Foreign Tax Credit after proper examination of Form 67.

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Issues: Whether the Foreign Tax Credit could be denied in processing under section 143(1) of the Income-tax Act, 1961, solely because Form 67 was filed after the due date prescribed under section 139(1) of the Income-tax Act, 1961.

Analysis: The return of income and Form 67 were both filed on the same date, and the record supported the claim for Foreign Tax Credit. The delay relied upon by the lower authority was treated as insufficient to deny the substantive entitlement to the credit. The adjustment made at the intimation stage was held to be unjustified in the facts of the case, and the matter was considered covered by prior tribunal decisions cited before the Tribunal.

Conclusion: The denial of Foreign Tax Credit was not sustained, and the assessee was held entitled to verification and grant of credit after proper examination of Form 67.

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