https://www.taxtmi.com/caselaws?id=780562 ITAT MUMBAI held that denial of foreign tax credit (FTC) solely for delayed filing of Form 67 was improper where only an intimation under Sec. 143(1) was issued and the assessee filed Form 67 before the Second Proviso period expired. The Tribunal treated filing under Rule 128(9) as directory, noted DTAA provisions prevail, and found the assessee was not put on notice as required by the Second Proviso to Sec. 143(1). It directed the AO to accept Form 67 and adjudicate the FTC claim on merits. 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 ITAT MUMBAI held that denial of foreign tax credit (FTC) solely for delayed filing of Form 67 was improper where only an intimation under Sec. 143(1) was issued and the assessee filed Form 67 before the Second Proviso period expired. The Tribunal treated filing under Rule 128(9) as directory, noted DTAA provisions prevail, and found the assessee was not put on notice as required by the Second Proviso to Sec. 143(1). It directed the AO to accept Form 67 and adjudicate the FTC claim on merits. Case-Laws Income Tax Tue, 30 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780562