https://www.taxtmi.com/caselaws?id=775939 Foreign tax credit under section 90 could not be denied merely because Form No. 67 was not filed with the original return. The Tribunal treated the filing timeline as a procedural requirement, not a condition precedent to the treaty-backed benefit, and noted that the form was later filed with the revised return. It held that neither section 90 nor the relevant tax treaty prescribed disallowance for such procedural non-compliance. The credit remained available, subject to verification, because a substantive entitlement cannot be lost for a curable default where the governing provision does not expressly bar relief. en-us Wed, 04 Jun 2025 00:00:00 +0530 Sat, 02 Aug 2025 07:24:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775939 Foreign tax credit under section 90 could not be denied merely because Form No. 67 was not filed with the original return. The Tribunal treated the filing timeline as a procedural requirement, not a condition precedent to the treaty-backed benefit, and noted that the form was later filed with the revised return. It held that neither section 90 nor the relevant tax treaty prescribed disallowance for such procedural non-compliance. The credit remained available, subject to verification, because a substantive entitlement cannot be lost for a curable default where the governing provision does not expressly bar relief. Case-Laws Income Tax Wed, 04 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775939