https://www.taxtmi.com/caselaws?id=755114 Rule 128's time-limit for filing Form No. 67 is procedural and does not extinguish the substantive right to foreign tax credit under sections 90 and 91. The Tribunal followed coordinate bench rulings and the Madras High Court's view that delayed filing of the form, where the revised return and Form No. 67 were filed before the section 143(1) intimation, cannot by itself justify denial of credit. It also affirmed that a beneficial DTAA prevails to the extent advantageous to the assessee, and procedural non-compliance cannot override the underlying credit entitlement. The denial of foreign tax credit for belated filing was therefore held unsustainable. en-us Mon, 03 Jun 2024 00:00:00 +0530 Fri, 05 Jul 2024 14:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755114 Rule 128's time-limit for filing Form No. 67 is procedural and does not extinguish the substantive right to foreign tax credit under sections 90 and 91. The Tribunal followed coordinate bench rulings and the Madras High Court's view that delayed filing of the form, where the revised return and Form No. 67 were filed before the section 143(1) intimation, cannot by itself justify denial of credit. It also affirmed that a beneficial DTAA prevails to the extent advantageous to the assessee, and procedural non-compliance cannot override the underlying credit entitlement. The denial of foreign tax credit for belated filing was therefore held unsustainable. Case-Laws Income Tax Mon, 03 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755114