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    <title>DENIAL OF FOREIGN TAX CREDIT</title>
    <link>https://www.taxtmi.com/article/detailed?id=11387</link>
    <description>Foreign tax credit under Rule 128 allows resident assessees credit for foreign taxes paid on income offered to tax in India, subject to Form No.67, foreign tax certificates and proof of payment/deduction, with credit limited to taxes in the nature of income-tax and excluding interest, fee or penalty. Multiple tribunals have treated filing of Form 67 as a directory requirement and recognised that delay alone does not extinguish the substantive right to treaty-based foreign tax credit where the income is taxed in India and foreign tax payment is evidenced.</description>
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    <pubDate>Wed, 10 May 2023 10:15:20 +0530</pubDate>
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      <link>https://www.taxtmi.com/article/detailed?id=11387</link>
      <description>Foreign tax credit under Rule 128 allows resident assessees credit for foreign taxes paid on income offered to tax in India, subject to Form No.67, foreign tax certificates and proof of payment/deduction, with credit limited to taxes in the nature of income-tax and excluding interest, fee or penalty. Multiple tribunals have treated filing of Form 67 as a directory requirement and recognised that delay alone does not extinguish the substantive right to treaty-based foreign tax credit where the income is taxed in India and foreign tax payment is evidenced.</description>
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      <pubDate>Wed, 10 May 2023 10:15:20 +0530</pubDate>
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