https://www.taxtmi.com/caselaws?id=783790 Foreign tax credit under section 90, rule 128(9) and Article 25(2)(a) of the India-USA DTAA was treated as a substantive treaty benefit, while filing Form 67 by the return due date was held to be only a procedural requirement. The rule was read as not creating any express disallowance for delay, so late filing could not defeat the assessee's entitlement to foreign tax credit where treaty relief was otherwise available. The credit was therefore allowed despite the delay in Form 67. en-us Thu, 24 Jul 2025 00:00:00 +0530 Tue, 23 Dec 2025 07:59:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783790 Foreign tax credit under section 90, rule 128(9) and Article 25(2)(a) of the India-USA DTAA was treated as a substantive treaty benefit, while filing Form 67 by the return due date was held to be only a procedural requirement. The rule was read as not creating any express disallowance for delay, so late filing could not defeat the assessee's entitlement to foreign tax credit where treaty relief was otherwise available. The credit was therefore allowed despite the delay in Form 67. Case-Laws Income Tax Thu, 24 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783790