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The ITAT held that despite the delay in filing Form 67 beyond the due date under section 139(1), the assessee was entitled to claim Foreign Tax Credit as the amount was disclosed in the original return. The delay was attributed to the COVID-19 pandemic and travel restrictions, constituting a reasonable cause beyond the assessee's control. The Tribunal emphasized that filing Form 67 is directory, not mandatory, and that the DTAA provisions prevail over the Act and Rules. Consequently, the assessee could invoke section 154 for rectification despite the original grievance lying against the intimation under section 143(1). On merits, the ITAT allowed the Foreign Tax Credit benefit, directing the revenue to grant the same.
The ITAT held that despite the delay in filing Form 67 beyond the due date under section 139(1), the assessee was entitled to claim Foreign Tax Credit as the amount was disclosed in the original return. The delay was attributed to the COVID-19 pandemic and travel restrictions, constituting a reasonable cause beyond the assessee's control. The Tribunal emphasized that filing Form 67 is directory, not mandatory, and that the DTAA provisions prevail over the Act and Rules. Consequently, the assessee could invoke section 154 for rectification despite the original grievance lying against the intimation under section 143(1). On merits, the ITAT allowed the Foreign Tax Credit benefit, directing the revenue to grant the same.
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