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    <title>Foreign tax credit claim survives delayed Form 67 filing, with ESOP taxation remanded on residential-status evidence.</title>
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    <description>Delayed filing of Form No. 67 did not, by itself, justify denial of foreign tax credit; the Tribunal treated the Rule 128 timeline as a directory procedural requirement and directed allowance of the claim subject to verification. The assessee&#039;s alternative plea that ESOP perquisites were not taxable in India because of his residential status was not examined on the additional passport and travel material; that issue was remitted for fresh adjudication after factual verification.</description>
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      <title>Foreign tax credit claim survives delayed Form 67 filing, with ESOP taxation remanded on residential-status evidence.</title>
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      <description>Delayed filing of Form No. 67 did not, by itself, justify denial of foreign tax credit; the Tribunal treated the Rule 128 timeline as a directory procedural requirement and directed allowance of the claim subject to verification. The assessee&#039;s alternative plea that ESOP perquisites were not taxable in India because of his residential status was not examined on the additional passport and travel material; that issue was remitted for fresh adjudication after factual verification.</description>
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