https://www.taxtmi.com/caselaws?id=465726 For the relevant pre-amendment period, delay in filing Form No. 67 under Rule 128(9) did not by itself justify denial of Foreign Tax Credit, as the time limit was treated as directory rather than mandatory. The Tribunal also held that an appellate order sustaining the denial was unsustainable where it relied on an incorrect rule reference, ignored the filed Form No. 67 and supporting material, and reflected non-application of mind and breach of natural justice. The matter was set aside and remitted for fresh verification of the Foreign Tax Credit claim. en-us Tue, 23 Apr 2024 00:00:00 +0530 Tue, 06 Jan 2026 10:40:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465726 For the relevant pre-amendment period, delay in filing Form No. 67 under Rule 128(9) did not by itself justify denial of Foreign Tax Credit, as the time limit was treated as directory rather than mandatory. The Tribunal also held that an appellate order sustaining the denial was unsustainable where it relied on an incorrect rule reference, ignored the filed Form No. 67 and supporting material, and reflected non-application of mind and breach of natural justice. The matter was set aside and remitted for fresh verification of the Foreign Tax Credit claim. Case-Laws Income Tax Tue, 23 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465726