<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>Rule 128(9) directory: Form 67 filed during appeal requires allowing foreign tax credit; AO to verify and grant</title>
    <link>https://www.taxtmi.com/highlights?id=92205</link>
    <description>The ITAT held that the time limit for filing Form 67 under Rule 128(9) is directory; where the taxpayer filed Form 67 during the pendency of the appeal before the CIT(A), the foreign tax credit should have been allowed. The matter is remitted to the AO to verify the claim and, if found in order, grant the foreign tax credit after due compliance. On carry-forward, the ITAT held that unabsorbed depreciation does not constitute a &quot;business loss&quot; for the relevant AY; the AO is directed to allow carry-forward losses for the earlier year in accordance with law after affording the assessee an opportunity of hearing. Ground No.3 allowed.</description>
    <language>en-us</language>
    <pubDate>Thu, 04 Sep 2025 08:40:36 +0530</pubDate>
    <lastBuildDate>Thu, 04 Sep 2025 08:40:37 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=847976" rel="self" type="application/rss+xml"/>
    <item>
      <title>Rule 128(9) directory: Form 67 filed during appeal requires allowing foreign tax credit; AO to verify and grant</title>
      <link>https://www.taxtmi.com/highlights?id=92205</link>
      <description>The ITAT held that the time limit for filing Form 67 under Rule 128(9) is directory; where the taxpayer filed Form 67 during the pendency of the appeal before the CIT(A), the foreign tax credit should have been allowed. The matter is remitted to the AO to verify the claim and, if found in order, grant the foreign tax credit after due compliance. On carry-forward, the ITAT held that unabsorbed depreciation does not constitute a &quot;business loss&quot; for the relevant AY; the AO is directed to allow carry-forward losses for the earlier year in accordance with law after affording the assessee an opportunity of hearing. Ground No.3 allowed.</description>
      <category>Highlights</category>
      <law>Income Tax</law>
      <pubDate>Thu, 04 Sep 2025 08:40:36 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/highlights?id=92205</guid>
    </item>
  </channel>
</rss>