https://www.taxtmi.com/caselaws?id=311774 The Tribunal allowed the appellant's appeal, overturning the denial of tax relief for Rs. 3,50,106/- paid in the Republic of Korea. The Tribunal found that the requirement to file Form No. 67 before the due date was directory, not mandatory, as no adverse consequences were specified for non-compliance. The appellant's eligibility for foreign tax credit was upheld since Form No. 67 was filed before the assessment proceedings concluded. The decision emphasized that procedural requirements without specified penalties for non-compliance should not obstruct substantive tax relief claims. The order was pronounced in Kolkata on 9th May, 2023. en-us Tue, 09 May 2023 00:00:00 +0530 Fri, 12 Jan 2024 08:42:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311774 The Tribunal allowed the appellant's appeal, overturning the denial of tax relief for Rs. 3,50,106/- paid in the Republic of Korea. The Tribunal found that the requirement to file Form No. 67 before the due date was directory, not mandatory, as no adverse consequences were specified for non-compliance. The appellant's eligibility for foreign tax credit was upheld since Form No. 67 was filed before the assessment proceedings concluded. The decision emphasized that procedural requirements without specified penalties for non-compliance should not obstruct substantive tax relief claims. The order was pronounced in Kolkata on 9th May, 2023. Case-Laws Income Tax Tue, 09 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311774