Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Foreign Tax Credit u/s 90/90A - - The Tribunal found that while the DTAA does not prescribe a filing requirement for FTC, the Income Tax Rules (Rule 128) do mandate the filing of Form No. 67 within a specified time limit. It emphasized that the purpose of this requirement is to verify the eligibility, genuineness, and correctness of the FTC claim. - The ITAT concluded that the filing of the claim form along with certificates and statements is mandatory concerning the essence of the FTC claim but directory regarding the time limit. It held that belated compliance does not warrant rejection or denial of the claim.
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