https://www.taxtmi.com/caselaws?id=793591 Belated filing of Form No. 67 did not disentitle an assessee from claiming Foreign Tax Credit under section 90 read with the applicable DTAA. The Tribunal held that Rule 128(9) prescribes the manner and timing of filing the form, but does not authorise denial of credit solely because the form was filed after the due date under section 139(1). It treated the requirement as procedural and directory, not mandatory, and ruled that treaty-based entitlement to credit cannot be defeated by that lapse. The DTAA was applied to the extent beneficial to the assessee, and the Foreign Tax Credit claim was accepted. en-us Fri, 15 May 2026 00:00:00 +0530 Fri, 19 Jun 2026 08:24:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793591 Belated filing of Form No. 67 did not disentitle an assessee from claiming Foreign Tax Credit under section 90 read with the applicable DTAA. The Tribunal held that Rule 128(9) prescribes the manner and timing of filing the form, but does not authorise denial of credit solely because the form was filed after the due date under section 139(1). It treated the requirement as procedural and directory, not mandatory, and ruled that treaty-based entitlement to credit cannot be defeated by that lapse. The DTAA was applied to the extent beneficial to the assessee, and the Foreign Tax Credit claim was accepted. Case-Laws Income Tax Fri, 15 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793591