https://www.taxtmi.com/caselaws?id=788853 Foreign tax credit under the treaty framework could not be denied merely because Form No. 67 was filed after the return due date. The ITAT held that Rule 128(9) prescribes the manner and time for furnishing the form, but does not state that delayed filing extinguishes the substantive credit. Filing Form No. 67 was treated as a procedural requirement, not a mandatory condition overriding treaty-based relief under section 90 of the Income-tax Act, 1961. Since the assessee had offered the foreign income to tax in India and claimed the credit on merits, the delay alone did not justify rejection of the claim. en-us Fri, 27 Mar 2026 00:00:00 +0530 Mon, 30 Mar 2026 08:48:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788853 Foreign tax credit under the treaty framework could not be denied merely because Form No. 67 was filed after the return due date. The ITAT held that Rule 128(9) prescribes the manner and time for furnishing the form, but does not state that delayed filing extinguishes the substantive credit. Filing Form No. 67 was treated as a procedural requirement, not a mandatory condition overriding treaty-based relief under section 90 of the Income-tax Act, 1961. Since the assessee had offered the foreign income to tax in India and claimed the credit on merits, the delay alone did not justify rejection of the claim. Case-Laws Income Tax Fri, 27 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788853