https://www.taxtmi.com/caselaws?id=767597 ITAT Delhi held that delayed filing of Form 67 after submitting return under section 139(1) does not warrant denial of Foreign Tax Credit. The tribunal ruled that Rule 128(9) does not provide for FTC disallowance due to delayed filing, Form 67 filing is directory rather than mandatory, and DTAA provisions override domestic rules. The AO was directed to accept the delayed Form 67 and allow FTC in accordance with law. Decision favored the assessee. en-us Fri, 24 Jan 2025 00:00:00 +0530 Fri, 21 Mar 2025 08:25:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767597 ITAT Delhi held that delayed filing of Form 67 after submitting return under section 139(1) does not warrant denial of Foreign Tax Credit. The tribunal ruled that Rule 128(9) does not provide for FTC disallowance due to delayed filing, Form 67 filing is directory rather than mandatory, and DTAA provisions override domestic rules. The AO was directed to accept the delayed Form 67 and allow FTC in accordance with law. Decision favored the assessee. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767597