https://www.taxtmi.com/caselaws?id=428529 The Tribunal partly allowed the appeal, directing the AO to grant the Foreign Tax Credit (FTC) based on Form 67 filed on 22/09/2018, despite the procedural delay. It emphasized that filing Form 67 is a directory, not mandatory, requirement, and should not negate substantive rights under the Double Taxation Avoidance Agreement (DTAA). The decision highlights that procedural norms should not override substantive rights granted by tax treaties. en-us Tue, 06 Sep 2022 00:00:00 +0530 Sat, 14 Sep 2024 10:07:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428529 The Tribunal partly allowed the appeal, directing the AO to grant the Foreign Tax Credit (FTC) based on Form 67 filed on 22/09/2018, despite the procedural delay. It emphasized that filing Form 67 is a directory, not mandatory, requirement, and should not negate substantive rights under the Double Taxation Avoidance Agreement (DTAA). The decision highlights that procedural norms should not override substantive rights granted by tax treaties. Case-Laws Income Tax Tue, 06 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428529