https://www.taxtmi.com/caselaws?id=465761 Foreign tax credit could not be denied merely because Form No. 67 was furnished after the due date, where the claim was already made in the return and the relevant figures were on record. Rule 128(9) was treated as procedural and directory rather than mandatory because it does not expressly provide forfeiture of credit for delay; the later extension of time to the end of the assessment year also supported that view. Where competing non-jurisdictional interpretations existed, the construction favourable to the assessee was applied, and the credit remained allowable despite belated filing. en-us Tue, 18 Apr 2023 00:00:00 +0530 Wed, 07 Jan 2026 20:50:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465761 Foreign tax credit could not be denied merely because Form No. 67 was furnished after the due date, where the claim was already made in the return and the relevant figures were on record. Rule 128(9) was treated as procedural and directory rather than mandatory because it does not expressly provide forfeiture of credit for delay; the later extension of time to the end of the assessment year also supported that view. Where competing non-jurisdictional interpretations existed, the construction favourable to the assessee was applied, and the credit remained allowable despite belated filing. Case-Laws Income Tax Tue, 18 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465761