The Appellate Tribunal (ITAT) considered the denial of Foreign...

The Appellate Tribunal (ITAT) considered the denial of Foreign Tax Credit (FTC) u/s late filing of Form 67. The assessee argued that Form 67 filing is procedural, not mandatory. ITAT held that Form 67 filing is directory, not mandatory, and non-compliance does not affect substantive rights. Orders below were set aside, directing the Assessing Officer to verify FTC claim upon accepting Form 67. The appeal of the assessee was allowed.