https://www.taxtmi.com/caselaws?id=763058 Foreign tax credit under section 90 and the applicable DTAA could not be denied merely because Form No. 67 was filed after the due date under rule 128(9), where the assessee had disclosed the foreign income and tax details in the return and the substantive entitlement to relief was otherwise established. The Tribunal held that the rule prescribes a procedural filing requirement and is directory, not mandatory, because it does not expressly provide that delay extinguishes the credit. Belated filing of Form No. 67 therefore did not defeat the treaty-based and statutory right to foreign tax credit, and the credit was allowable in accordance with law. en-us Fri, 06 Dec 2024 00:00:00 +0530 Tue, 12 May 2026 10:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763058 Foreign tax credit under section 90 and the applicable DTAA could not be denied merely because Form No. 67 was filed after the due date under rule 128(9), where the assessee had disclosed the foreign income and tax details in the return and the substantive entitlement to relief was otherwise established. The Tribunal held that the rule prescribes a procedural filing requirement and is directory, not mandatory, because it does not expressly provide that delay extinguishes the credit. Belated filing of Form No. 67 therefore did not defeat the treaty-based and statutory right to foreign tax credit, and the credit was allowable in accordance with law. Case-Laws Income Tax Fri, 06 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763058