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    <description>Delay in filing the first appeal was condonable where the assessee showed a bona fide explanation based on reliance on a tax consultant and lack of timely awareness of the adverse order. Foreign tax credit under section 90 and Article 24 of the India-Sri Lanka DTAA could not be denied merely because Form No. 67 was filed late, as Rule 128(9) was treated as directory and the treaty-based substantive entitlement prevailed subject to verification. The claim for carry forward of house property loss was not examined earlier and was remitted for verification and decision in accordance with law.</description>
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