https://www.taxtmi.com/caselaws?id=434760 The tribunal allowed the appeal, condoning the delay in filing and directing the AO to grant the Foreign Tax Credit (FTC) of Rs. 36,25,781 to the appellant. The tribunal considered the late filing of Form 67 as a directory requirement, not mandatory, referencing relevant case law. It held that debatable issues like the FTC should not be adjusted under Section 143(1) and emphasized the importance of providing a defense opportunity in proceedings under Section 143(1) of the Income-tax Act. en-us Tue, 28 Feb 2023 00:00:00 +0530 Thu, 02 Mar 2023 13:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434760 The tribunal allowed the appeal, condoning the delay in filing and directing the AO to grant the Foreign Tax Credit (FTC) of Rs. 36,25,781 to the appellant. The tribunal considered the late filing of Form 67 as a directory requirement, not mandatory, referencing relevant case law. It held that debatable issues like the FTC should not be adjusted under Section 143(1) and emphasized the importance of providing a defense opportunity in proceedings under Section 143(1) of the Income-tax Act. Case-Laws Income Tax Tue, 28 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434760