https://www.taxtmi.com/caselaws?id=468151 Rule 128 of the Income Tax Rules, 1962 is treated as directory for claiming Foreign Tax Credit, so delayed filing of Form 67 does not by itself defeat the substantive credit claim. Where the return was filed within time and Form 67 was submitted later, the assessee's entitlement to credit for tax paid in the United States on dividend income was preserved. The denial of Foreign Tax Credit at the processing stage for non-compliance with the due date was set aside, on the basis that Rule 128 operates as a procedural mechanism to implement Section 90 of the Income-tax Act, 1961 rather than a mandatory condition that extinguishes the credit. en-us Wed, 18 Jun 2025 00:00:00 +0530 Fri, 17 Apr 2026 22:39:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468151 Rule 128 of the Income Tax Rules, 1962 is treated as directory for claiming Foreign Tax Credit, so delayed filing of Form 67 does not by itself defeat the substantive credit claim. Where the return was filed within time and Form 67 was submitted later, the assessee's entitlement to credit for tax paid in the United States on dividend income was preserved. The denial of Foreign Tax Credit at the processing stage for non-compliance with the due date was set aside, on the basis that Rule 128 operates as a procedural mechanism to implement Section 90 of the Income-tax Act, 1961 rather than a mandatory condition that extinguishes the credit. Case-Laws Income Tax Wed, 18 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468151