https://www.taxtmi.com/caselaws?id=792503 Delay in filing Form No. 67 did not by itself justify denial of foreign tax credit under section 90 read with rule 128(9). The Tribunal treated the form as a procedural requirement and held that belated filing could not defeat the assessee's substantive treaty-based entitlement to credit. It further recognised that the Double Taxation Avoidance Agreement prevails to the extent it is more beneficial, so the procedural rule could not override relief available under section 90. The claim for foreign tax credit was therefore sustained despite the delay, and the appeal was allowed. en-us Mon, 27 Apr 2026 00:00:00 +0530 Thu, 28 May 2026 17:27:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792503 Delay in filing Form No. 67 did not by itself justify denial of foreign tax credit under section 90 read with rule 128(9). The Tribunal treated the form as a procedural requirement and held that belated filing could not defeat the assessee's substantive treaty-based entitlement to credit. It further recognised that the Double Taxation Avoidance Agreement prevails to the extent it is more beneficial, so the procedural rule could not override relief available under section 90. The claim for foreign tax credit was therefore sustained despite the delay, and the appeal was allowed. Case-Laws Income Tax Mon, 27 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792503