https://www.taxtmi.com/caselaws?id=467977 A one-day delay in filing Form 67 was treated as a procedural lapse and did not defeat the assessee's substantive entitlement to relief under section 90 of the Income-tax Act. In the absence of express statutory language making timely filing mandatory and prescribing disqualification for late filing, technical non-compliance could not be used to deny foreign tax credit or other treaty relief. The delay was therefore required to be condoned, and relief could not be refused solely on that ground. en-us Wed, 29 May 2024 00:00:00 +0530 Fri, 10 Apr 2026 20:17:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467977 A one-day delay in filing Form 67 was treated as a procedural lapse and did not defeat the assessee's substantive entitlement to relief under section 90 of the Income-tax Act. In the absence of express statutory language making timely filing mandatory and prescribing disqualification for late filing, technical non-compliance could not be used to deny foreign tax credit or other treaty relief. The delay was therefore required to be condoned, and relief could not be refused solely on that ground. Case-Laws Income Tax Wed, 29 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467977