https://www.taxtmi.com/caselaws?id=783749 The dominant issue was whether foreign tax credit could be denied solely because Form 67 was filed belatedly. Applying HC authority, the Tribunal held that Rule 128's requirement to furnish Form 67 is directory and intended to facilitate implementation of the Act rather than create a mandatory condition precedent. Drawing an analogy from SC jurisprudence treating belated filing of a prescribed form during assessment as sufficient compliance, it found that delayed submission did not defeat the substantive entitlement to FTC. Consequently, the denial of FTC was set aside and the AO was directed to grant the credit; the appeal was allowed. en-us Fri, 19 Dec 2025 00:00:00 +0530 Mon, 22 Dec 2025 07:49:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783749 The dominant issue was whether foreign tax credit could be denied solely because Form 67 was filed belatedly. Applying HC authority, the Tribunal held that Rule 128's requirement to furnish Form 67 is directory and intended to facilitate implementation of the Act rather than create a mandatory condition precedent. Drawing an analogy from SC jurisprudence treating belated filing of a prescribed form during assessment as sufficient compliance, it found that delayed submission did not defeat the substantive entitlement to FTC. Consequently, the denial of FTC was set aside and the AO was directed to grant the credit; the appeal was allowed. Case-Laws Income Tax Fri, 19 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783749