https://www.taxtmi.com/caselaws?id=468655 Delay in filing Form 67 under Rule 128 does not, by itself, extinguish a treaty-based foreign tax credit claim under section 90 where the substantive entitlement is otherwise established. The Tribunal treated the filing deadline as directory, not mandatory, and held that a procedural lapse could not defeat the assessee's underlying right to credit for foreign tax paid. It further held that the denial could not be sustained as a rectification issue under section 154 because the claim required verification on merits after acceptance of Form 67. The matter was restored for fresh examination in accordance with law. en-us Thu, 06 Feb 2025 00:00:00 +0530 Fri, 15 May 2026 20:34:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468655 Delay in filing Form 67 under Rule 128 does not, by itself, extinguish a treaty-based foreign tax credit claim under section 90 where the substantive entitlement is otherwise established. The Tribunal treated the filing deadline as directory, not mandatory, and held that a procedural lapse could not defeat the assessee's underlying right to credit for foreign tax paid. It further held that the denial could not be sustained as a rectification issue under section 154 because the claim required verification on merits after acceptance of Form 67. The matter was restored for fresh examination in accordance with law. Case-Laws Income Tax Thu, 06 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468655