https://www.taxtmi.com/caselaws?id=775868 The ITAT Delhi held that delay in filing Form 67 for claiming Foreign Tax Credit (FTC) does not warrant denial of the credit. The tribunal observed that Rule 128(9) does not mandate disallowance of FTC due to late submission of Form 67, which is a directory, not mandatory, requirement. Further, the DTAA provisions override the Act, and the Rules cannot contradict the Act. Consequently, the AO was directed to allow the FTC claimed by the assessee. The appeal was allowed. en-us Wed, 30 Jul 2025 00:00:00 +0530 Fri, 01 Aug 2025 08:15:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775868 The ITAT Delhi held that delay in filing Form 67 for claiming Foreign Tax Credit (FTC) does not warrant denial of the credit. The tribunal observed that Rule 128(9) does not mandate disallowance of FTC due to late submission of Form 67, which is a directory, not mandatory, requirement. Further, the DTAA provisions override the Act, and the Rules cannot contradict the Act. Consequently, the AO was directed to allow the FTC claimed by the assessee. The appeal was allowed. Case-Laws Income Tax Wed, 30 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775868