https://www.taxtmi.com/caselaws?id=458101 The ITAT Delhi held that Form 67 filing for Foreign Tax Credit (FTC) is a procedural directory requirement, not mandatory. Following precedent in Vikash Daga case, the tribunal ruled that procedural violations do not extinguish substantive rights to claim FTC. The ITAT directed the AO to allow FTC, noting that DTAA provisions override domestic rules and Rule 128(9) does not provide for FTC disallowance due to delayed Form 67 filing. The matter was remanded to the assessing authority for verification and grant of foreign tax credit. The assessee's appeal was allowed for statistical purposes. en-us Mon, 11 Sep 2023 00:00:00 +0530 Tue, 08 Oct 2024 07:30:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=458101 The ITAT Delhi held that Form 67 filing for Foreign Tax Credit (FTC) is a procedural directory requirement, not mandatory. Following precedent in Vikash Daga case, the tribunal ruled that procedural violations do not extinguish substantive rights to claim FTC. The ITAT directed the AO to allow FTC, noting that DTAA provisions override domestic rules and Rule 128(9) does not provide for FTC disallowance due to delayed Form 67 filing. The matter was remanded to the assessing authority for verification and grant of foreign tax credit. The assessee's appeal was allowed for statistical purposes. Case-Laws Income Tax Mon, 11 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=458101