https://www.taxtmi.com/caselaws?id=468152 Delay in filing Form 67 does not by itself justify denial of foreign tax credit where the tax paid outside India and the underlying claim are otherwise disclosed in the return. Rule 128(9) of the Income-tax Rules, 1962 was read as not prescribing any adverse consequence for delayed filing, and the Form 67 requirement was treated as directory rather than mandatory. Sections 90 and 91 of the Income-tax Act, 1961 were noted to contain no timeline for furnishing the declaration, and the treaty position under the DTAA supported allowance of the credit. The foreign tax credit was therefore to be allowed, subject only to verification of the claim. en-us Mon, 16 Feb 2026 00:00:00 +0530 Fri, 17 Apr 2026 22:39:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468152 Delay in filing Form 67 does not by itself justify denial of foreign tax credit where the tax paid outside India and the underlying claim are otherwise disclosed in the return. Rule 128(9) of the Income-tax Rules, 1962 was read as not prescribing any adverse consequence for delayed filing, and the Form 67 requirement was treated as directory rather than mandatory. Sections 90 and 91 of the Income-tax Act, 1961 were noted to contain no timeline for furnishing the declaration, and the treaty position under the DTAA supported allowance of the credit. The foreign tax credit was therefore to be allowed, subject only to verification of the claim. Case-Laws Income Tax Mon, 16 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468152