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    <title>2025 (1) TMI 1065 - ITAT PUNE</title>
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    <description>Foreign Tax Credit could not be denied merely because Form No. 67 was filed after the due date under section 139(1) where the form was submitted before processing of the return and the claim was otherwise supported by the return and treaty provisions. Rule 128 was treated as directory and procedural, so delayed filing did not defeat the substantive entitlement to credit. The credit was therefore directed to be allowed, subject to due verification.</description>
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      <description>Foreign Tax Credit could not be denied merely because Form No. 67 was filed after the due date under section 139(1) where the form was submitted before processing of the return and the claim was otherwise supported by the return and treaty provisions. Rule 128 was treated as directory and procedural, so delayed filing did not defeat the substantive entitlement to credit. The credit was therefore directed to be allowed, subject to due verification.</description>
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