https://www.taxtmi.com/caselaws?id=463510 Foreign tax credit under the treaty could not be denied merely because Form No. 67 was filed after the return due date, where the form was already on record before processing of the return. Rule 128 filing was treated as procedural and directory, meant to facilitate administration of the claim, not as a condition precedent that could defeat substantive credit. On that basis, the belated filing of Form No. 67 did not justify denial of the foreign tax credit, and the credit was required to be allowed. en-us Mon, 23 Dec 2024 00:00:00 +0530 Thu, 04 Sep 2025 19:12:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463510 Foreign tax credit under the treaty could not be denied merely because Form No. 67 was filed after the return due date, where the form was already on record before processing of the return. Rule 128 filing was treated as procedural and directory, meant to facilitate administration of the claim, not as a condition precedent that could defeat substantive credit. On that basis, the belated filing of Form No. 67 did not justify denial of the foreign tax credit, and the credit was required to be allowed. Case-Laws Income Tax Mon, 23 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463510