https://www.taxtmi.com/caselaws?id=768476 Foreign Tax Credit under section 91 of the Income-tax Act could not be denied merely because Form 67 was filed after the return due date. The requirement to file Form 67 within the section 139(1) deadline was treated as procedural and directory, not mandatory, and treaty credit under the Double Taxation Avoidance Agreement was held to prevail over the Rules where foreign tax had been paid. The delayed filing of Form 67, by itself, was therefore not a valid ground to reject the substantive credit. en-us Fri, 07 Mar 2025 00:00:00 +0530 Tue, 08 Apr 2025 08:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768476 Foreign Tax Credit under section 91 of the Income-tax Act could not be denied merely because Form 67 was filed after the return due date. The requirement to file Form 67 within the section 139(1) deadline was treated as procedural and directory, not mandatory, and treaty credit under the Double Taxation Avoidance Agreement was held to prevail over the Rules where foreign tax had been paid. The delayed filing of Form 67, by itself, was therefore not a valid ground to reject the substantive credit. Case-Laws Income Tax Fri, 07 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768476