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    <title>2026 (4) TMI 838 - ITAT MUMBAI</title>
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    <description>Delay in filing Form No. 67 under Rule 128(9) was treated as procedural rather than fatal to the substantive claim for foreign tax credit under section 90 where the foreign income, tax paid abroad, and supporting documents were disclosed and later furnished during rectification. The Tribunal held that delayed filing alone did not extinguish entitlement to credit, particularly when the claim remained capable of verification on merits. The denial was set aside and the Assessing Officer was directed to examine the foreign tax credit claim after accepting Form No. 67 and the related documents.</description>
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      <description>Delay in filing Form No. 67 under Rule 128(9) was treated as procedural rather than fatal to the substantive claim for foreign tax credit under section 90 where the foreign income, tax paid abroad, and supporting documents were disclosed and later furnished during rectification. The Tribunal held that delayed filing alone did not extinguish entitlement to credit, particularly when the claim remained capable of verification on merits. The denial was set aside and the Assessing Officer was directed to examine the foreign tax credit claim after accepting Form No. 67 and the related documents.</description>
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