https://www.taxtmi.com/caselaws?id=443863 Delay of 710 days in filing the appeal before the CIT(A) was condoned because the assessee showed sufficient cause arising from the pandemic period and the prior pursuit of rectification under section 154; the appeal had been rejected only on limitation, so the merits were not examined. Foreign Tax Credit claimed under section 90 read with Article 25(2)(a) of the India-USA DTAA could not be denied for delayed filing of Form 67, because Rule 128(9) was held to be directory and subordinate to the Act and treaty. The assessee was therefore granted the claimed Foreign Tax Credit. en-us Tue, 26 Sep 2023 00:00:00 +0530 Tue, 03 Oct 2023 11:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443863 Delay of 710 days in filing the appeal before the CIT(A) was condoned because the assessee showed sufficient cause arising from the pandemic period and the prior pursuit of rectification under section 154; the appeal had been rejected only on limitation, so the merits were not examined. Foreign Tax Credit claimed under section 90 read with Article 25(2)(a) of the India-USA DTAA could not be denied for delayed filing of Form 67, because Rule 128(9) was held to be directory and subordinate to the Act and treaty. The assessee was therefore granted the claimed Foreign Tax Credit. Case-Laws Income Tax Tue, 26 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443863