https://www.taxtmi.com/caselaws?id=780562 Rule 128(9) prescribes the filing timeline for Form No. 67, but the delay is not, by itself, a statutory bar to foreign tax credit where the Act does not attach denial as a consequence. The filing requirement is treated as directory, so foreign tax credit cannot be refused solely because Form No. 67 was filed late. A summary adjustment under section 143(1) also cannot sustain denial of foreign tax credit without notice and an opportunity to respond under the proviso to section 143(1)(a). The matter therefore requires fresh consideration on merits after due opportunity. en-us Tue, 30 Sep 2025 00:00:00 +0530 Sat, 01 Nov 2025 08:17:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780562 Rule 128(9) prescribes the filing timeline for Form No. 67, but the delay is not, by itself, a statutory bar to foreign tax credit where the Act does not attach denial as a consequence. The filing requirement is treated as directory, so foreign tax credit cannot be refused solely because Form No. 67 was filed late. A summary adjustment under section 143(1) also cannot sustain denial of foreign tax credit without notice and an opportunity to respond under the proviso to section 143(1)(a). The matter therefore requires fresh consideration on merits after due opportunity. Case-Laws Income Tax Tue, 30 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780562