https://www.taxtmi.com/caselaws?id=791266 Belated filing of Form 67 under Rule 128 is a directory procedural requirement and does not, by itself, defeat a substantive Foreign Tax Credit claim under section 90 and the applicable DTAA where foreign tax has actually been paid and the claim is otherwise verifiable in law. The remaining additions for the assessment year were found insufficiently reasoned and were set aside for fresh examination by the Assessing Officer after giving the assessee an opportunity of being heard. The article therefore states that procedural delay in Form 67 does not extinguish treaty-based credit entitlement, while the other disputed matters were remanded for de novo consideration. 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 Belated filing of Form 67 under Rule 128 is a directory procedural requirement and does not, by itself, defeat a substantive Foreign Tax Credit claim under section 90 and the applicable DTAA where foreign tax has actually been paid and the claim is otherwise verifiable in law. The remaining additions for the assessment year were found insufficiently reasoned and were set aside for fresh examination by the Assessing Officer after giving the assessee an opportunity of being heard. The article therefore states that procedural delay in Form 67 does not extinguish treaty-based credit entitlement, while the other disputed matters were remanded for de novo consideration. Case-Laws Income Tax Wed, 06 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791266