https://www.taxtmi.com/caselaws?id=754273 Foreign tax credit under section 90 of the Income-tax Act, 1961 and the applicable DTAA cannot be denied merely because Form No. 67 was filed late. Rule 128 of the Income-tax Rules, 1962 was treated as prescribing a procedural and directory filing requirement, not a mandatory condition that extinguishes the substantive treaty-based entitlement to relief. Where the claim for taxes paid outside India is otherwise supported by the record, delayed compliance with Form No. 67 does not defeat foreign tax credit, and the more beneficial treaty provisions prevail over the domestic procedural rule to that extent. en-us Wed, 12 Jun 2024 00:00:00 +0530 Wed, 19 Jun 2024 11:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754273 Foreign tax credit under section 90 of the Income-tax Act, 1961 and the applicable DTAA cannot be denied merely because Form No. 67 was filed late. Rule 128 of the Income-tax Rules, 1962 was treated as prescribing a procedural and directory filing requirement, not a mandatory condition that extinguishes the substantive treaty-based entitlement to relief. Where the claim for taxes paid outside India is otherwise supported by the record, delayed compliance with Form No. 67 does not defeat foreign tax credit, and the more beneficial treaty provisions prevail over the domestic procedural rule to that extent. Case-Laws Income Tax Wed, 12 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754273