https://www.taxtmi.com/caselaws?id=754870 ITAT Indore ruled in favor of the assessee regarding foreign tax credit (FTC) denial due to late filing of Form 67. The tribunal held that filing Form 67 under Rule 128 is directory, not mandatory, following precedents from Madras HC and ITAT Bangalore. The tribunal emphasized that DTAA provisions override domestic rules, and delay in filing Form 67 cannot result in FTC disallowance. The AO was directed to allow the FTC claim after quantum verification. Appeal allowed for statistical purposes. en-us Fri, 28 Jun 2024 00:00:00 +0530 Mon, 01 Jul 2024 14:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754870 ITAT Indore ruled in favor of the assessee regarding foreign tax credit (FTC) denial due to late filing of Form 67. The tribunal held that filing Form 67 under Rule 128 is directory, not mandatory, following precedents from Madras HC and ITAT Bangalore. The tribunal emphasized that DTAA provisions override domestic rules, and delay in filing Form 67 cannot result in FTC disallowance. The AO was directed to allow the FTC claim after quantum verification. Appeal allowed for statistical purposes. Case-Laws Income Tax Fri, 28 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754870