https://www.taxtmi.com/caselaws?id=774673 ITAT Delhi ruled in favor of the assessee regarding denial of Foreign Tax Credit (FTC) relief under sections 90/91 for non-filing of Form 67 as prescribed under Rule 128. The tribunal held that FTC is a vested right under DTAA and section 90, which cannot be disallowed for procedural non-compliance. Following consistent ITAT precedents from Bangalore, Jaipur, and Mumbai benches, the court determined that filing Form 67 is directory, not mandatory, as rules cannot override the Act's provisions. en-us Thu, 05 Jun 2025 00:00:00 +0530 Sat, 12 Jul 2025 08:40:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774673 ITAT Delhi ruled in favor of the assessee regarding denial of Foreign Tax Credit (FTC) relief under sections 90/91 for non-filing of Form 67 as prescribed under Rule 128. The tribunal held that FTC is a vested right under DTAA and section 90, which cannot be disallowed for procedural non-compliance. Following consistent ITAT precedents from Bangalore, Jaipur, and Mumbai benches, the court determined that filing Form 67 is directory, not mandatory, as rules cannot override the Act's provisions. Case-Laws Income Tax Thu, 05 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774673