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    <title>2026 (4) TMI 768 - ITAT DELHI</title>
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    <description>Belated filing of Form 67 under Rule 128(9) was treated as a directory, not mandatory, compliance requirement for claiming Foreign Tax Credit under sections 90 and 90A. The commentary states that where the underlying entitlement to credit is otherwise satisfied, delayed filing of the form should not defeat the substantive claim merely because it was lodged after the section 139(1) due date. The filing lapse was described as a curable procedural default, and the delay was directed to be condoned, leaving the assessee entitled to the credit.</description>
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      <link>https://www.taxtmi.com/caselaws?id=789699</link>
      <description>Belated filing of Form 67 under Rule 128(9) was treated as a directory, not mandatory, compliance requirement for claiming Foreign Tax Credit under sections 90 and 90A. The commentary states that where the underlying entitlement to credit is otherwise satisfied, delayed filing of the form should not defeat the substantive claim merely because it was lodged after the section 139(1) due date. The filing lapse was described as a curable procedural default, and the delay was directed to be condoned, leaving the assessee entitled to the credit.</description>
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