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    <title>2024 (6) TMI 1282 - ITAT BANGALORE</title>
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    <description>Foreign tax credit under the treaty-based relief framework could not be denied solely because Form No. 67 was filed after the due date for the return. The filing requirement was treated as procedural and directory, since the rule did not expressly state that late filing extinguished the substantive credit. The assessee&#039;s entitlement was therefore to be examined on verification of the form already filed, and credit was to be allowed on due verification.</description>
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      <description>Foreign tax credit under the treaty-based relief framework could not be denied solely because Form No. 67 was filed after the due date for the return. The filing requirement was treated as procedural and directory, since the rule did not expressly state that late filing extinguished the substantive credit. The assessee&#039;s entitlement was therefore to be examined on verification of the form already filed, and credit was to be allowed on due verification.</description>
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