https://www.taxtmi.com/caselaws?id=431965 Foreign tax credit could not be denied merely because Form 67 was filed after the return due date, as Rule 128(9) requires timely filing but does not state that delay extinguishes the substantive credit entitlement. The treaty framework under Article 25 of the India-USA DTAA and the principle that a procedural lapse should not defeat an otherwise established foreign tax liability supported the taxpayer's claim, so the revenue's disallowance was unsustainable. en-us Tue, 20 Dec 2022 00:00:00 +0530 Fri, 23 Dec 2022 10:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431965 Foreign tax credit could not be denied merely because Form 67 was filed after the return due date, as Rule 128(9) requires timely filing but does not state that delay extinguishes the substantive credit entitlement. The treaty framework under Article 25 of the India-USA DTAA and the principle that a procedural lapse should not defeat an otherwise established foreign tax liability supported the taxpayer's claim, so the revenue's disallowance was unsustainable. Case-Laws Income Tax Tue, 20 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431965