https://www.taxtmi.com/caselaws?id=789406 Form 67 filing by the due date is treated as a procedural requirement for claiming foreign tax credit under the Income-tax Act and the India-South Africa DTAA. The analysis relies on the principle that treaty benefits prevail where the assessee is otherwise substantively entitled to relief, and on the view that late filing of Form 67 does not by itself defeat the credit claim. On the stated facts, the form was filed before the revised return, so the delayed filing was not treated as a bar to foreign tax credit. en-us Wed, 25 Mar 2026 00:00:00 +0530 Wed, 08 Apr 2026 08:56:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789406 Form 67 filing by the due date is treated as a procedural requirement for claiming foreign tax credit under the Income-tax Act and the India-South Africa DTAA. The analysis relies on the principle that treaty benefits prevail where the assessee is otherwise substantively entitled to relief, and on the view that late filing of Form 67 does not by itself defeat the credit claim. On the stated facts, the form was filed before the revised return, so the delayed filing was not treated as a bar to foreign tax credit. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789406