https://www.taxtmi.com/caselaws?id=438778 Rule 128 governing Form No. 67 is procedural and directory, so delayed filing of the return or the form by itself does not extinguish a taxpayer's treaty-based entitlement to foreign tax credit under section 90. The Tribunal treated the foreign tax credit claim as not liable to denial solely for that delay, but it required fresh verification of whether the relevant salary income was actually earned outside India and whether foreign tax was paid on that income, as those facts were necessary to determine the extent of credit admissible. en-us Tue, 06 Jun 2023 00:00:00 +0530 Thu, 08 Jun 2023 09:09:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438778 Rule 128 governing Form No. 67 is procedural and directory, so delayed filing of the return or the form by itself does not extinguish a taxpayer's treaty-based entitlement to foreign tax credit under section 90. The Tribunal treated the foreign tax credit claim as not liable to denial solely for that delay, but it required fresh verification of whether the relevant salary income was actually earned outside India and whether foreign tax was paid on that income, as those facts were necessary to determine the extent of credit admissible. Case-Laws Income Tax Tue, 06 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438778