https://www.taxtmi.com/caselaws?id=311793 Foreign tax credit could not be denied merely because Form 67 was filed after the due date under section 139(1), since Rule 128 was treated as procedural and directory rather than a substantive condition for relief. The assessee had offered the foreign income to tax in India and paid tax in the United Kingdom, so treaty-based relief under sections 90 and 91 remained available. The resulting disallowance was therefore an error apparent from the record, and rectification under section 154 was warranted. en-us Wed, 10 May 2023 00:00:00 +0530 Sat, 13 Jan 2024 08:35:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311793 Foreign tax credit could not be denied merely because Form 67 was filed after the due date under section 139(1), since Rule 128 was treated as procedural and directory rather than a substantive condition for relief. The assessee had offered the foreign income to tax in India and paid tax in the United Kingdom, so treaty-based relief under sections 90 and 91 remained available. The resulting disallowance was therefore an error apparent from the record, and rectification under section 154 was warranted. Case-Laws Income Tax Wed, 10 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311793