https://www.taxtmi.com/caselaws?id=463038 Foreign Tax Credit could not be denied merely because Form 67 was filed after the return under section 139(1). Rule 128(9) was treated as procedural and directory, not a mandatory condition for disallowance, so a belated filing did not extinguish the substantive FTC entitlement. The Tribunal also noted that treaty relief under article 25(2)(a) of the India-USA DTAA, read with section 90 of the Income-tax Act, could not be defeated by this procedural lapse. Accordingly, delay in filing Form 67 alone was insufficient to deny the credit, and the assessee remained entitled to FTC. en-us Fri, 24 Jan 2025 00:00:00 +0530 Fri, 01 Aug 2025 22:57:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463038 Foreign Tax Credit could not be denied merely because Form 67 was filed after the return under section 139(1). Rule 128(9) was treated as procedural and directory, not a mandatory condition for disallowance, so a belated filing did not extinguish the substantive FTC entitlement. The Tribunal also noted that treaty relief under article 25(2)(a) of the India-USA DTAA, read with section 90 of the Income-tax Act, could not be defeated by this procedural lapse. Accordingly, delay in filing Form 67 alone was insufficient to deny the credit, and the assessee remained entitled to FTC. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463038