https://www.taxtmi.com/caselaws?id=467955 Belated filing of Form No. 67 under Rule 128 does not, by itself, defeat an assessee's claim for foreign tax credit under section 90. The requirement to furnish Form No. 67 on or before the due date under section 139(1) was treated as procedural, because neither section 90 nor Rule 128 expressly provides that delay extinguishes the substantive entitlement to relief. The absence of any express statutory consequence for late filing, unlike provisions that specifically deny deductions or reliefs for non-compliance, supported the view that the time limit is directory rather than mandatory. The foreign tax credit remained allowable. en-us Wed, 28 Jun 2023 00:00:00 +0530 Fri, 10 Apr 2026 14:33:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467955 Belated filing of Form No. 67 under Rule 128 does not, by itself, defeat an assessee's claim for foreign tax credit under section 90. The requirement to furnish Form No. 67 on or before the due date under section 139(1) was treated as procedural, because neither section 90 nor Rule 128 expressly provides that delay extinguishes the substantive entitlement to relief. The absence of any express statutory consequence for late filing, unlike provisions that specifically deny deductions or reliefs for non-compliance, supported the view that the time limit is directory rather than mandatory. The foreign tax credit remained allowable. Case-Laws Income Tax Wed, 28 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467955