https://www.taxtmi.com/caselaws?id=446109 Form 67 under Rule 128 for foreign tax credit was treated as a procedural requirement linked to the implementation of a substantive tax benefit under Sections 90 and 91 of the Income-tax Act read with Article 24 of the India-Kenya DTAA. Where the assessee uploaded the form before completion of processing under Section 143(1), the principle of substantial compliance applied and the delayed filing did not defeat the underlying credit claim. On that reasoning, rejection of foreign tax credit solely for late filing of Form 67 was unsustainable, the disallowance was set aside, and the matter was remitted for reconsideration. en-us Fri, 06 Oct 2023 00:00:00 +0530 Sat, 20 Dec 2025 13:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446109 Form 67 under Rule 128 for foreign tax credit was treated as a procedural requirement linked to the implementation of a substantive tax benefit under Sections 90 and 91 of the Income-tax Act read with Article 24 of the India-Kenya DTAA. Where the assessee uploaded the form before completion of processing under Section 143(1), the principle of substantial compliance applied and the delayed filing did not defeat the underlying credit claim. On that reasoning, rejection of foreign tax credit solely for late filing of Form 67 was unsustainable, the disallowance was set aside, and the matter was remitted for reconsideration. Case-Laws Income Tax Fri, 06 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446109