https://www.taxtmi.com/caselaws?id=791266 Foreign Tax Credit under section 90 and the applicable DTAA is a substantive entitlement where foreign tax has been paid and the claim is otherwise verifiable. Rule 128's requirement to file Form 67 by the prescribed due date is procedural and directory; delayed filing alone does not defeat the credit claim, subject to verification in accordance with law. Remaining disputed additions require fresh examination where appellate reasoning is insufficient. They should be set aside for de novo assessment after the assessee receives an opportunity of being heard, without a final determination on their merits. en-us Wed, 06 May 2026 00:00:00 +0530 Fri, 08 May 2026 07:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791266 Foreign Tax Credit under section 90 and the applicable DTAA is a substantive entitlement where foreign tax has been paid and the claim is otherwise verifiable. Rule 128's requirement to file Form 67 by the prescribed due date is procedural and directory; delayed filing alone does not defeat the credit claim, subject to verification in accordance with law. Remaining disputed additions require fresh examination where appellate reasoning is insufficient. They should be set aside for de novo assessment after the assessee receives an opportunity of being heard, without a final determination on their merits. Case-Laws Income Tax Wed, 06 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791266