https://www.taxtmi.com/caselaws?id=766281 Foreign Tax Credit could not be denied merely because Form 67 was filed after the due date under section 139(1). The Tribunal treated the filing requirement as procedural and directory, not as a condition that extinguishes the substantive entitlement to credit under the Act and the DTAA. Where the underlying claim to Foreign Tax Credit otherwise existed, delayed filing of Form 67 by itself was insufficient to justify rejection. The credit was therefore required to be allowed notwithstanding the delay. en-us Wed, 19 Feb 2025 00:00:00 +0530 Fri, 21 Feb 2025 08:23:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766281 Foreign Tax Credit could not be denied merely because Form 67 was filed after the due date under section 139(1). The Tribunal treated the filing requirement as procedural and directory, not as a condition that extinguishes the substantive entitlement to credit under the Act and the DTAA. Where the underlying claim to Foreign Tax Credit otherwise existed, delayed filing of Form 67 by itself was insufficient to justify rejection. The credit was therefore required to be allowed notwithstanding the delay. Case-Laws Income Tax Wed, 19 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766281