https://www.taxtmi.com/caselaws?id=763051 Foreign tax credit under section 90 of the Income-tax Act, 1961, read with the applicable DTAA, cannot be denied solely because Form No. 67 was filed after the time prescribed in Rule 128(9) of the Income-tax Rules, 1962. The rule regulates the manner and timeline for furnishing the form, but it does not create a substantive bar or extinguish treaty-based relief for delayed filing. Where the taxpayer has paid tax abroad, offered the related income in India, and the relevant details are available for verification, the credit remains allowable. The delayed filing of Form No. 67 therefore did not justify denial of foreign tax credit, and the credit was directed to be granted in accordance with law. en-us Tue, 19 Nov 2024 00:00:00 +0530 Tue, 12 May 2026 10:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763051 Foreign tax credit under section 90 of the Income-tax Act, 1961, read with the applicable DTAA, cannot be denied solely because Form No. 67 was filed after the time prescribed in Rule 128(9) of the Income-tax Rules, 1962. The rule regulates the manner and timeline for furnishing the form, but it does not create a substantive bar or extinguish treaty-based relief for delayed filing. Where the taxpayer has paid tax abroad, offered the related income in India, and the relevant details are available for verification, the credit remains allowable. The delayed filing of Form No. 67 therefore did not justify denial of foreign tax credit, and the credit was directed to be granted in accordance with law. Case-Laws Income Tax Tue, 19 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763051