https://www.taxtmi.com/caselaws?id=763274 The ITAT Bangalore held that denial of foreign tax credit solely due to delayed filing of Form No.67 beyond the due date under Rule 128 of IT Rules, 1962 was incorrect. Following precedent in Vinod Kumar Lakshmipathi case, the Tribunal ruled that Rule 128(9) does not mandate disallowance for delayed filing, Form No.67 filing is directory rather than mandatory, and DTAA provisions override domestic rules. The AO was directed to allow foreign tax credit after verification of the belatedly filed Form No.67. The assessee's appeal was partly allowed. en-us Wed, 31 Jul 2024 00:00:00 +0530 Tue, 17 Dec 2024 08:42:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763274 The ITAT Bangalore held that denial of foreign tax credit solely due to delayed filing of Form No.67 beyond the due date under Rule 128 of IT Rules, 1962 was incorrect. Following precedent in Vinod Kumar Lakshmipathi case, the Tribunal ruled that Rule 128(9) does not mandate disallowance for delayed filing, Form No.67 filing is directory rather than mandatory, and DTAA provisions override domestic rules. The AO was directed to allow foreign tax credit after verification of the belatedly filed Form No.67. The assessee's appeal was partly allowed. Case-Laws Income Tax Wed, 31 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763274