https://www.taxtmi.com/caselaws?id=427981 Foreign tax credit under section 90 could not be denied merely because Form 67 was filed after the due date under Rule 128(9). The text treats the filing requirement as procedural and directory, not a substantive condition that extinguishes the treaty-based credit. It notes that the India-Finland DTAA, particularly Article 22(2), obliges India to allow credit for foreign tax within the treaty limit, and that rule-making power under section 295 does not authorise adding a disqualification not found in the Act or treaty. Where the credit was otherwise available on record before assessment, a delayed Form 67 filing did not defeat relief. en-us Thu, 15 Sep 2022 00:00:00 +0530 Tue, 28 Nov 2023 14:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427981 Foreign tax credit under section 90 could not be denied merely because Form 67 was filed after the due date under Rule 128(9). The text treats the filing requirement as procedural and directory, not a substantive condition that extinguishes the treaty-based credit. It notes that the India-Finland DTAA, particularly Article 22(2), obliges India to allow credit for foreign tax within the treaty limit, and that rule-making power under section 295 does not authorise adding a disqualification not found in the Act or treaty. Where the credit was otherwise available on record before assessment, a delayed Form 67 filing did not defeat relief. Case-Laws Income Tax Thu, 15 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427981