https://www.taxtmi.com/caselaws?id=753155 Foreign tax credit under section 90 read with Article 25(2)(a) of the India-USA DTAA was held to be a substantive entitlement available to the extent of Indian tax payable. Rule 128(9) requiring filing of Form 67 was treated as procedural and directory, so belated or initially incorrect filing did not extinguish the credit claim. The disallowance was therefore unsustainable, and the assessee remained entitled to foreign tax credit within the statutory limit. en-us Fri, 24 May 2024 00:00:00 +0530 Sat, 25 May 2024 11:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753155 Foreign tax credit under section 90 read with Article 25(2)(a) of the India-USA DTAA was held to be a substantive entitlement available to the extent of Indian tax payable. Rule 128(9) requiring filing of Form 67 was treated as procedural and directory, so belated or initially incorrect filing did not extinguish the credit claim. The disallowance was therefore unsustainable, and the assessee remained entitled to foreign tax credit within the statutory limit. Case-Laws Income Tax Fri, 24 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753155