https://www.taxtmi.com/caselaws?id=442409 The Appellate Tribunal ruled in favor of the assessee, holding that the delay in filing Form 67 for the Foreign Tax Credit claim should not result in denial of the claim. The Tribunal considered the filing of Form 67 as a procedural requirement, not a mandatory one, emphasizing that the Double Taxation Avoidance Agreement prevails over domestic laws. The Tribunal directed the Assessing Officer to allow the Foreign Tax Credit to the assessee based on legal interpretation and precedents, contrary to the Commissioner's decision to deny the claim. en-us Tue, 29 Aug 2023 00:00:00 +0530 Fri, 01 Sep 2023 08:55:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442409 The Appellate Tribunal ruled in favor of the assessee, holding that the delay in filing Form 67 for the Foreign Tax Credit claim should not result in denial of the claim. The Tribunal considered the filing of Form 67 as a procedural requirement, not a mandatory one, emphasizing that the Double Taxation Avoidance Agreement prevails over domestic laws. The Tribunal directed the Assessing Officer to allow the Foreign Tax Credit to the assessee based on legal interpretation and precedents, contrary to the Commissioner's decision to deny the claim. Case-Laws Income Tax Tue, 29 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442409