https://www.taxtmi.com/caselaws?id=459498 ITAT Hyderabad allowed the assessee's appeal regarding disallowance of Foreign Tax Credit under section 90 for non-filing of Form No. 67. The Tribunal held that Rule 128(9) does not provide for FTC disallowance due to delayed filing, Form No. 67 filing is directory rather than mandatory, and DTAA provisions override domestic rules. The decision followed precedent from Ashish Agarwal case, which remained unstayed by higher courts. en-us Fri, 22 Mar 2024 00:00:00 +0530 Tue, 17 Dec 2024 08:41:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459498 ITAT Hyderabad allowed the assessee's appeal regarding disallowance of Foreign Tax Credit under section 90 for non-filing of Form No. 67. The Tribunal held that Rule 128(9) does not provide for FTC disallowance due to delayed filing, Form No. 67 filing is directory rather than mandatory, and DTAA provisions override domestic rules. The decision followed precedent from Ashish Agarwal case, which remained unstayed by higher courts. Case-Laws Income Tax Fri, 22 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459498