https://www.taxtmi.com/caselaws?id=314417 The ITAT DELHI allowed the appeal, ruling that the delay in filing Form 67, a procedural requirement, should not result in the denial of the foreign tax credit claimed under Section 90 of the Act. The Tribunal held that procedural norms do not nullify the substantive right to claim foreign tax credit, and the DTAA overrides conflicting provisions of the Act. Consequently, the AO was directed to grant the foreign tax credit, thereby favoring the appellant. en-us Wed, 14 Jun 2023 00:00:00 +0530 Fri, 07 Jun 2024 20:46:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314417 The ITAT DELHI allowed the appeal, ruling that the delay in filing Form 67, a procedural requirement, should not result in the denial of the foreign tax credit claimed under Section 90 of the Act. The Tribunal held that procedural norms do not nullify the substantive right to claim foreign tax credit, and the DTAA overrides conflicting provisions of the Act. Consequently, the AO was directed to grant the foreign tax credit, thereby favoring the appellant. Case-Laws Income Tax Wed, 14 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314417