https://www.taxtmi.com/caselaws?id=449709 The ITAT Bangalore allowed FTC u/s 90 despite delayed filing of Form 67. The assessee filed a revised return after initially omitting Form 67 and made unsuccessful attempts for rectification through CPC. Following Vinodkumar Lakshmipathi precedent, the tribunal held that Rule 128(9) doesn't mandate FTC disallowance for delayed Form 67 filing, the form is directory not mandatory, and DTAA provisions override contradictory rules. The AO was directed to grant foreign tax credit per the belatedly filed Form 67. en-us Tue, 05 Dec 2023 00:00:00 +0530 Sat, 17 Feb 2024 09:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449709 The ITAT Bangalore allowed FTC u/s 90 despite delayed filing of Form 67. The assessee filed a revised return after initially omitting Form 67 and made unsuccessful attempts for rectification through CPC. Following Vinodkumar Lakshmipathi precedent, the tribunal held that Rule 128(9) doesn't mandate FTC disallowance for delayed Form 67 filing, the form is directory not mandatory, and DTAA provisions override contradictory rules. The AO was directed to grant foreign tax credit per the belatedly filed Form 67. Case-Laws Income Tax Tue, 05 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449709