https://www.taxtmi.com/caselaws?id=776639 Rule 128 on Foreign Tax Credit was treated as procedural, not as creating any disallowance for delayed filing of Form 67. The filing requirement under section 139(1) was held to regulate the manner of claiming relief, not to extinguish the substantive right to credit where foreign tax was actually paid and the related income was offered to tax. Relief under section 90 and the treaty was said to prevent double taxation, so the Form 67 deadline was read as directory rather than mandatory. The Foreign Tax Credit claim was therefore allowed after verification. en-us Thu, 10 Jul 2025 00:00:00 +0530 Thu, 14 Aug 2025 08:26:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776639 Rule 128 on Foreign Tax Credit was treated as procedural, not as creating any disallowance for delayed filing of Form 67. The filing requirement under section 139(1) was held to regulate the manner of claiming relief, not to extinguish the substantive right to credit where foreign tax was actually paid and the related income was offered to tax. Relief under section 90 and the treaty was said to prevent double taxation, so the Form 67 deadline was read as directory rather than mandatory. The Foreign Tax Credit claim was therefore allowed after verification. Case-Laws Income Tax Thu, 10 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776639