Foreign tax credit for Australian employment income cannot be...

Foreign tax credit for Australian employment income cannot be denied solely because a belated return and Form No. 67 were filed late where substantive entitlement and compliance with other required formalities are undisputed. Rule 128's timing requirement is treated as a directory procedural condition in subordinate legislation and cannot curtail substantive entitlement to foreign tax credit. The credit claim was consequently required to be accepted, and the denial was set aside.