https://www.taxtmi.com/caselaws?id=772764 ITAT Bangalore held that denial of Foreign Tax Credit (FTC) based solely on late submission of Form 67 violates DTAA provisions. The Tribunal ruled that Rule 128(9) does not mandate disallowance of FTC for delayed filing, Form 67 filing is directory rather than mandatory, and DTAA overrides domestic rules. Following precedent in Ms. Brinda Ramakrishna case, the assessee was granted FTC entitlement with directions to AO for verification and allowance. en-us Tue, 22 Apr 2025 00:00:00 +0530 Fri, 13 Jun 2025 08:41:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772764 ITAT Bangalore held that denial of Foreign Tax Credit (FTC) based solely on late submission of Form 67 violates DTAA provisions. The Tribunal ruled that Rule 128(9) does not mandate disallowance of FTC for delayed filing, Form 67 filing is directory rather than mandatory, and DTAA overrides domestic rules. Following precedent in Ms. Brinda Ramakrishna case, the assessee was granted FTC entitlement with directions to AO for verification and allowance. Case-Laws Income Tax Tue, 22 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772764