https://www.taxtmi.com/caselaws?id=307044 Rule 128(9) of the Income-tax Rules prescribes the time for filing Form No. 67, but it does not create a separate disallowance for late filing. The Tribunal treated the requirement as procedural and directory, and held that the substantive entitlement to foreign tax credit under the applicable DTAA and section 90 of the Income-tax Act cannot be curtailed by the Rules. Late filing of Form No. 67 was therefore not fatal to the claim, and the credit could be examined and granted in rectification proceedings. en-us Mon, 19 Sep 2022 00:00:00 +0530 Tue, 14 Mar 2023 21:44:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307044 Rule 128(9) of the Income-tax Rules prescribes the time for filing Form No. 67, but it does not create a separate disallowance for late filing. The Tribunal treated the requirement as procedural and directory, and held that the substantive entitlement to foreign tax credit under the applicable DTAA and section 90 of the Income-tax Act cannot be curtailed by the Rules. Late filing of Form No. 67 was therefore not fatal to the claim, and the credit could be examined and granted in rectification proceedings. Case-Laws Income Tax Mon, 19 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307044