https://www.taxtmi.com/caselaws?id=787634 Foreign tax credit (FTC) denial based solely on delayed filing of Form-67 was rejected; the controlling legal principle is that DTAA provisions and statutory scheme (Sections 90/91 and Article 25(2)(a) of the India US DTAA) require consideration of FTC where substantive compliance and supporting evidence exist. Rule 128(9) was treated as directory by reference to precedents, and inconsistent decisions were distinguished. Outcome: matter remitted to Assessing Officer to verify submitted documents and decide the FTC claim on merits rather than refuse it solely for delay. en-us Fri, 06 Mar 2026 00:00:00 +0530 Tue, 10 Mar 2026 08:51:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787634 Foreign tax credit (FTC) denial based solely on delayed filing of Form-67 was rejected; the controlling legal principle is that DTAA provisions and statutory scheme (Sections 90/91 and Article 25(2)(a) of the India US DTAA) require consideration of FTC where substantive compliance and supporting evidence exist. Rule 128(9) was treated as directory by reference to precedents, and inconsistent decisions were distinguished. Outcome: matter remitted to Assessing Officer to verify submitted documents and decide the FTC claim on merits rather than refuse it solely for delay. Case-Laws Income Tax Fri, 06 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787634