https://www.taxtmi.com/caselaws?id=768666 Article 23 of the India-Nepal Double Taxation Avoidance Agreement requires India to grant credit against Indian tax for Nepal tax paid on income taxable in Nepal, subject to the prescribed ceiling. Where the foreign income and tax payment are established, this treaty-based entitlement is not extinguished solely by delayed filing of Form No. 67 under Rule 128. The more beneficial treaty provision prevails over inconsistent domestic procedural requirements, so belated filing cannot by itself bar foreign tax credit. en-us Mon, 18 Nov 2024 00:00:00 +0530 Wed, 30 Sep 2026 10:41:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768666 Article 23 of the India-Nepal Double Taxation Avoidance Agreement requires India to grant credit against Indian tax for Nepal tax paid on income taxable in Nepal, subject to the prescribed ceiling. Where the foreign income and tax payment are established, this treaty-based entitlement is not extinguished solely by delayed filing of Form No. 67 under Rule 128. The more beneficial treaty provision prevails over inconsistent domestic procedural requirements, so belated filing cannot by itself bar foreign tax credit. Case-Laws Income Tax Mon, 18 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768666