https://www.taxtmi.com/caselaws?id=793645 Belated filing of Form No. 67 was treated as insufficient, by itself, to completely bar a foreign tax credit claim for U.S. tax paid on ESOP-related income. The Tribunal also noted the assessee's alternative contention that the ESOP perquisite may not be taxable in India in view of residential status, and that additional evidence had been filed before the first appellate authority. As the residential status and corresponding taxability issues required factual verification, the matter was remitted to the Assessing Officer for fresh examination of the foreign tax credit claim and the alternative plea after considering the additional material. en-us Thu, 14 May 2026 00:00:00 +0530 Sat, 20 Jun 2026 08:04:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793645 Belated filing of Form No. 67 was treated as insufficient, by itself, to completely bar a foreign tax credit claim for U.S. tax paid on ESOP-related income. The Tribunal also noted the assessee's alternative contention that the ESOP perquisite may not be taxable in India in view of residential status, and that additional evidence had been filed before the first appellate authority. As the residential status and corresponding taxability issues required factual verification, the matter was remitted to the Assessing Officer for fresh examination of the foreign tax credit claim and the alternative plea after considering the additional material. Case-Laws Income Tax Thu, 14 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793645