https://www.taxtmi.com/caselaws?id=779735 Foreign Tax Credit could not be denied merely because Form No. 67 was filed after the Rule 128(9) deadline, as the filing deadline was treated as procedural rather than mandatory. The underlying credit arose from section 90 and the relevant DTAA, so the delayed form did not extinguish the substantive treaty-based entitlement. Interest under sections 234A, 234B and 234C, being consequential to the denied credit, also could not survive once the credit was allowed. Relief was therefore granted on the Foreign Tax Credit claim with corresponding adjustment to the tax computation. en-us Tue, 07 Oct 2025 00:00:00 +0530 Sat, 11 Oct 2025 09:01:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779735 Foreign Tax Credit could not be denied merely because Form No. 67 was filed after the Rule 128(9) deadline, as the filing deadline was treated as procedural rather than mandatory. The underlying credit arose from section 90 and the relevant DTAA, so the delayed form did not extinguish the substantive treaty-based entitlement. Interest under sections 234A, 234B and 234C, being consequential to the denied credit, also could not survive once the credit was allowed. Relief was therefore granted on the Foreign Tax Credit claim with corresponding adjustment to the tax computation. Case-Laws Income Tax Tue, 07 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779735