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ITAT ruled that denial of Foreign Tax Credit (FTC) based solely on late submission of Form 67 contravenes Double Taxation Avoidance Agreement (DTAA) principles. The tribunal determined that Rule 128(9) does not mandate disallowing FTC for delayed Form 67 filing, characterizing such filing as a directory rather than mandatory requirement. Referencing prior judicial precedent, ITAT emphasized that DTAA provisions supersede domestic tax regulations. Consequently, the appellate tribunal directed the Assessing Officer to verify and grant FTC to the assessee, affirming the taxpayer's entitlement to foreign tax credit despite procedural delay.
ITAT ruled that denial of Foreign Tax Credit (FTC) based solely on late submission of Form 67 contravenes Double Taxation Avoidance Agreement (DTAA) principles. The tribunal determined that Rule 128(9) does not mandate disallowing FTC for delayed Form 67 filing, characterizing such filing as a directory rather than mandatory requirement. Referencing prior judicial precedent, ITAT emphasized that DTAA provisions supersede domestic tax regulations. Consequently, the appellate tribunal directed the Assessing Officer to verify and grant FTC to the assessee, affirming the taxpayer's entitlement to foreign tax credit despite procedural delay.
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