https://www.taxtmi.com/caselaws?id=760884 Delay in filing Form 67 for foreign tax credit was treated as capable of condonation where the explanation for non-compliance was bona fide, including difficulty in obtaining foreign documents during the Covid period. Rule 128 governing Form 67 was regarded as directory, not mandatory, because it implements the substantive relief available under Sections 90, 90A and 91. On that basis, rejection of the foreign tax credit claim solely for delayed filing was held unsustainable, and the claim was required to be reconsidered on merits. The impugned order was set aside and the matter remitted for reassessment after considering the credit claim. en-us Thu, 26 Sep 2024 00:00:00 +0530 Mon, 28 Oct 2024 12:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760884 Delay in filing Form 67 for foreign tax credit was treated as capable of condonation where the explanation for non-compliance was bona fide, including difficulty in obtaining foreign documents during the Covid period. Rule 128 governing Form 67 was regarded as directory, not mandatory, because it implements the substantive relief available under Sections 90, 90A and 91. On that basis, rejection of the foreign tax credit claim solely for delayed filing was held unsustainable, and the claim was required to be reconsidered on merits. The impugned order was set aside and the matter remitted for reassessment after considering the credit claim. Case-Laws Income Tax Thu, 26 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760884