Foreign Tax Credit claim cannot be rejected solely for delayed filing of Form No. 67, if evidence supports the claim.

Foreign Tax Credit cannot be denied merely because Form No. 67 was filed after the due date, where the underlying claim is supported by evidence and the foreign taxes paid are not in dispute. The Tribunal followed its earlier view that filing Form No. 67 is directory, not mandatory, so delayed filing by itself does not defeat the credit. The Assessing Officer was directed to allow the claim after verification.

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Issues: Whether Foreign Tax Credit could be denied solely because Form No. 67 was filed after the due date of filing the return of income.

Analysis: The claim for Foreign Tax Credit was rejected only on the ground of delayed filing of Form No. 67, without any dispute as to the underlying claim or the supporting particulars. The Tribunal followed its earlier decisions holding that filing of Form No. 67 is directory and not mandatory, and that where foreign taxes have been paid and the claim is otherwise supported by evidence, the credit cannot be denied merely for delay in filing the form.

Conclusion: The assessee's claim for Foreign Tax Credit could not be rejected solely for belated filing of Form No. 67, and the Assessing Officer was directed to allow the claim after verification.

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