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    <title>2025 (10) TMI 409 - ITAT DELHI</title>
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    <description>Filing Form 67 after the due date for filing the return under section 139(1) was treated as a directory, not mandatory, requirement for claiming foreign tax credit. On that basis, late filing by itself was held insufficient to deny the credit. The Tribunal also noted that the factual position required fresh verification, so the matter was restored to the Assessing Officer for examination and consequential recomputation in accordance with law. The disallowance of foreign tax credit in rectification proceedings under section 154 was therefore not sustained on the stated ground.</description>
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      <link>https://www.taxtmi.com/caselaws?id=779613</link>
      <description>Filing Form 67 after the due date for filing the return under section 139(1) was treated as a directory, not mandatory, requirement for claiming foreign tax credit. On that basis, late filing by itself was held insufficient to deny the credit. The Tribunal also noted that the factual position required fresh verification, so the matter was restored to the Assessing Officer for examination and consequential recomputation in accordance with law. The disallowance of foreign tax credit in rectification proceedings under section 154 was therefore not sustained on the stated ground.</description>
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