https://www.taxtmi.com/caselaws?id=787634 Delay in filing Form 67 under Rule 128(9) was treated as directory rather than mandatory, so Foreign Tax Credit could not be denied solely on that procedural ground where foreign income, tax payment, and supporting particulars were disclosed. The Tribunal applied its consistent view that treaty relief under the Double Taxation Avoidance Agreement prevails over inconsistent procedural requirements in the Rules. The claim was therefore to be considered on the basis of the Form 67 already filed, and the matter was remanded to the Assessing Officer for verification and decision in accordance with law. 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 Delay in filing Form 67 under Rule 128(9) was treated as directory rather than mandatory, so Foreign Tax Credit could not be denied solely on that procedural ground where foreign income, tax payment, and supporting particulars were disclosed. The Tribunal applied its consistent view that treaty relief under the Double Taxation Avoidance Agreement prevails over inconsistent procedural requirements in the Rules. The claim was therefore to be considered on the basis of the Form 67 already filed, and the matter was remanded to the Assessing Officer for verification and decision in accordance with law. Case-Laws Income Tax Fri, 06 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787634