https://www.taxtmi.com/caselaws?id=752485 The ITAT upheld the CIT(A)'s decision to allow the appellant's Foreign Tax Credit claim despite the delayed filing of Form 67. The tribunal emphasized that Rule 128 is directory, not mandatory, and the DTAA overrides the Income Tax Act. The appellant's filing of Form 67 prior to the order rendered the Revenue's appeal meritless, leading to its dismissal. en-us Thu, 09 May 2024 00:00:00 +0530 Sat, 11 May 2024 08:35:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752485 The ITAT upheld the CIT(A)'s decision to allow the appellant's Foreign Tax Credit claim despite the delayed filing of Form 67. The tribunal emphasized that Rule 128 is directory, not mandatory, and the DTAA overrides the Income Tax Act. The appellant's filing of Form 67 prior to the order rendered the Revenue's appeal meritless, leading to its dismissal. Case-Laws Income Tax Thu, 09 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752485