https://www.taxtmi.com/caselaws?id=765420 Delay in filing Form 67 under Rule 128(9) is treated as a procedural lapse and, by itself, does not extinguish the substantive claim for Foreign Tax Credit under section 90 and the relevant DTAA. The filing deadline is described as a machinery requirement rather than a condition that determines the existence of the credit entitlement. Accordingly, late submission of Form 67 should not, on its own, justify rejection of the Foreign Tax Credit claim where the underlying treaty-based entitlement is otherwise available in law. en-us Wed, 29 Jan 2025 00:00:00 +0530 Sat, 20 Dec 2025 13:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765420 Delay in filing Form 67 under Rule 128(9) is treated as a procedural lapse and, by itself, does not extinguish the substantive claim for Foreign Tax Credit under section 90 and the relevant DTAA. The filing deadline is described as a machinery requirement rather than a condition that determines the existence of the credit entitlement. Accordingly, late submission of Form 67 should not, on its own, justify rejection of the Foreign Tax Credit claim where the underlying treaty-based entitlement is otherwise available in law. Case-Laws Income Tax Wed, 29 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765420