https://www.taxtmi.com/caselaws?id=788367 Denial of foreign tax credit solely for delayed filing of Form No.67 is unsustainable; a procedural lapse does not extinguish the substantive right to relief under a Double Taxation Avoidance Agreement. The correct approach is verification of underlying facts and records, not automatic rejection for a technical delay. The matter is remitted to the assessing officer for limited factual verification and, if the claim is substantiated by records, grant of the foreign tax credit. The operative effect is that technical delay alone cannot be the sole basis for disallowing treaty relief. en-us Wed, 18 Mar 2026 00:00:00 +0530 Fri, 20 Mar 2026 08:35:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788367 Denial of foreign tax credit solely for delayed filing of Form No.67 is unsustainable; a procedural lapse does not extinguish the substantive right to relief under a Double Taxation Avoidance Agreement. The correct approach is verification of underlying facts and records, not automatic rejection for a technical delay. The matter is remitted to the assessing officer for limited factual verification and, if the claim is substantiated by records, grant of the foreign tax credit. The operative effect is that technical delay alone cannot be the sole basis for disallowing treaty relief. Case-Laws Income Tax Wed, 18 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788367