https://www.taxtmi.com/caselaws?id=756786 The ITAT Delhi ruled in favor of the assessee regarding disallowance of Foreign Tax Credit (FTC) despite failure to file Form No. 67 before the due date under section 139(1). The tribunal held that Rule 128(9) provisions are directory in nature and cannot override section 90 of the Act. Following the precedent in Bhaskar Dutta case, the tribunal determined that Rule 128(9) does not bar FTC claims due to delayed filing of Form No. 67. The Assessing Officer was directed to grant FTC after factual verification. The assessee's appeal was allowed. en-us Tue, 06 Aug 2024 00:00:00 +0530 Thu, 08 Aug 2024 17:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756786 The ITAT Delhi ruled in favor of the assessee regarding disallowance of Foreign Tax Credit (FTC) despite failure to file Form No. 67 before the due date under section 139(1). The tribunal held that Rule 128(9) provisions are directory in nature and cannot override section 90 of the Act. Following the precedent in Bhaskar Dutta case, the tribunal determined that Rule 128(9) does not bar FTC claims due to delayed filing of Form No. 67. The Assessing Officer was directed to grant FTC after factual verification. The assessee's appeal was allowed. Case-Laws Income Tax Tue, 06 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756786