https://www.taxtmi.com/caselaws?id=433323 Belated filing of Form No. 67 for foreign tax credit under Rule 128 is treated as a procedural irregularity and not a bar to substantive relief where the underlying treaty entitlement is otherwise available under Section 90 read with the relevant tax treaty. The Tribunal preferred the view that the form-filing requirement, though couched in mandatory language, should not extinguish the resident assessee's right to foreign tax credit merely because the form was filed after the due date under Section 139(1). The assessee was therefore entitled to the foreign tax credit and consequential refund. en-us Fri, 02 Dec 2022 00:00:00 +0530 Fri, 27 Jan 2023 08:33:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433323 Belated filing of Form No. 67 for foreign tax credit under Rule 128 is treated as a procedural irregularity and not a bar to substantive relief where the underlying treaty entitlement is otherwise available under Section 90 read with the relevant tax treaty. The Tribunal preferred the view that the form-filing requirement, though couched in mandatory language, should not extinguish the resident assessee's right to foreign tax credit merely because the form was filed after the due date under Section 139(1). The assessee was therefore entitled to the foreign tax credit and consequential refund. Case-Laws Income Tax Fri, 02 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433323