https://www.taxtmi.com/caselaws?id=459340 Delay in furnishing Form No. 67 under Rule 128(9) did not extinguish the substantive right to foreign tax credit under section 90 and Article 25 of the India-Singapore DTAA. The filing requirement was treated as procedural and directory, not mandatory, so a belated return of Form No. 67 could not override treaty-based relief. The disallowance of foreign tax credit for taxes paid in Singapore was therefore unsustainable, and the relief was to be granted in accordance with law and the DTAA. 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 Delay in furnishing Form No. 67 under Rule 128(9) did not extinguish the substantive right to foreign tax credit under section 90 and Article 25 of the India-Singapore DTAA. The filing requirement was treated as procedural and directory, not mandatory, so a belated return of Form No. 67 could not override treaty-based relief. The disallowance of foreign tax credit for taxes paid in Singapore was therefore unsustainable, and the relief was to be granted in accordance with law and the DTAA. Case-Laws Income Tax Fri, 26 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459340