Foreign tax credit cannot be denied for delayed Form 67 filing when taxes paid and particulars are verifiable.

Foreign tax credit cannot be denied merely because Form No. 67 was filed after the return-filing due date, where the foreign taxes paid and supporting particulars are otherwise verifiable. The ITAT Pune followed its coordinate bench rulings and held that filing Form No. 67 is directory, not mandatory, so procedural delay alone does not defeat a substantive FTC claim. The denial of relief on belated filing was therefore unsustainable, and the Assessing Officer was directed to verify the claim and allow the foreign tax credit.

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Issues: Whether the assessee was entitled to foreign tax credit despite filing Form No. 67 after the due date prescribed under the income-tax return filing provisions.

Analysis: The claim for foreign tax credit was denied only on the ground that Form No. 67 was filed belatedly. The Tribunal followed its earlier coordinate bench decisions holding that filing of Form No. 67 is directory and not mandatory, and that delay in filing the form, by itself, cannot defeat a substantive claim for foreign tax credit when the foreign taxes paid and the supporting particulars are otherwise verifiable. On that basis, the denial of relief was found unsustainable.

Conclusion: The assessee was held entitled to foreign tax credit, and the Assessing Officer was directed to verify the claim and allow it.

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