https://www.taxtmi.com/caselaws?id=312806 Delayed filing of Form 67 under rule 128 does not, by itself, justify denial of foreign tax credit where the underlying tax has been paid abroad and the income has also been taxed in India. The procedural filing requirement was treated as directory rather than mandatory, so the credit could still be allowed subject to verification. The refusal to grant credit was also held to be capable of correction in rectification proceedings under section 154 because it was not a debatable issue on the settled legal position. The Assessing Officer was directed to allow the foreign tax credit claimed. en-us Wed, 29 Mar 2023 00:00:00 +0530 Sat, 09 Mar 2024 06:56:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312806 Delayed filing of Form 67 under rule 128 does not, by itself, justify denial of foreign tax credit where the underlying tax has been paid abroad and the income has also been taxed in India. The procedural filing requirement was treated as directory rather than mandatory, so the credit could still be allowed subject to verification. The refusal to grant credit was also held to be capable of correction in rectification proceedings under section 154 because it was not a debatable issue on the settled legal position. The Assessing Officer was directed to allow the foreign tax credit claimed. Case-Laws Income Tax Wed, 29 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312806