https://www.taxtmi.com/caselaws?id=459368 Foreign tax credit under section 90(2) and the relevant DTAA was treated as a substantive treaty entitlement that could not be denied merely because Form No. 67 was filed after the due date under rule 128(9). The filing requirement was regarded as procedural, and the rules did not prescribe disallowance for delayed compliance. As Form No. 67 had been furnished before completion of assessment, the procedural lapse did not extinguish the credit claim, and the foreign tax credit was directed to be allowed. en-us Wed, 24 Apr 2024 00:00:00 +0530 Tue, 10 Dec 2024 16:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459368 Foreign tax credit under section 90(2) and the relevant DTAA was treated as a substantive treaty entitlement that could not be denied merely because Form No. 67 was filed after the due date under rule 128(9). The filing requirement was regarded as procedural, and the rules did not prescribe disallowance for delayed compliance. As Form No. 67 had been furnished before completion of assessment, the procedural lapse did not extinguish the credit claim, and the foreign tax credit was directed to be allowed. Case-Laws Income Tax Wed, 24 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459368