https://www.taxtmi.com/caselaws?id=459340 ITAT Kolkata ruled in favor of the assessee regarding delayed foreign tax credit claim. Despite late submission of Form 67, the tribunal held that DTAA provisions override domestic tax law provisions under Section 90 when more beneficial to the assessee. The court determined that foreign tax credit is a vested right and Rule 128(a) does not preclude claims due to delayed filing. Since Form 67 was submitted in response to CPC query, the tribunal directed the AO to allow FTC as per India-Singapore DTAA. Appeal allowed. en-us Fri, 26 Jul 2024 00:00:00 +0530 Tue, 10 Dec 2024 08:53:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459340 ITAT Kolkata ruled in favor of the assessee regarding delayed foreign tax credit claim. Despite late submission of Form 67, the tribunal held that DTAA provisions override domestic tax law provisions under Section 90 when more beneficial to the assessee. The court determined that foreign tax credit is a vested right and Rule 128(a) does not preclude claims due to delayed filing. Since Form 67 was submitted in response to CPC query, the tribunal directed the AO to allow FTC as per India-Singapore DTAA. Appeal allowed. Case-Laws Income Tax Fri, 26 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459340