https://www.taxtmi.com/caselaws?id=764510 The ITAT Ahmedabad allowed the assessee's appeal regarding foreign tax credit claimed under Section 90. The Revenue denied the claim due to late filing of Form No. 67 beyond the due date under Section 139(1). The ITAT held that delay in filing Form No. 67 cannot deny the assessee's vested right to claim foreign tax credit under the Double Tax Agreement. Following precedent in Chiragkumar Nandalal Makadia, the tribunal ruled that Form No. 67 filing is merely a procedural requirement under Rule 128, and procedural delays cannot result in denial of substantive foreign tax credit benefits available under international tax treaties. en-us Thu, 09 Jan 2025 00:00:00 +0530 Sat, 11 Jan 2025 08:46:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764510 The ITAT Ahmedabad allowed the assessee's appeal regarding foreign tax credit claimed under Section 90. The Revenue denied the claim due to late filing of Form No. 67 beyond the due date under Section 139(1). The ITAT held that delay in filing Form No. 67 cannot deny the assessee's vested right to claim foreign tax credit under the Double Tax Agreement. Following precedent in Chiragkumar Nandalal Makadia, the tribunal ruled that Form No. 67 filing is merely a procedural requirement under Rule 128, and procedural delays cannot result in denial of substantive foreign tax credit benefits available under international tax treaties. Case-Laws Income Tax Thu, 09 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764510