<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2026 (7) TMI 44 - ITAT KOLKATA</title>
    <link>https://www.taxtmi.com/caselaws?id=794158</link>
    <description>Foreign tax credit under section 90 is discussed as not being denied solely because Form No. 67 was filed after the rule 128(9) due date. The text states that the delayed filing was treated as a procedural lapse, not a substantive defect that extinguishes entitlement to credit. It further notes the view that rule 128(9) is directory and cannot override the statutory right to foreign tax credit under the Act and the applicable DTAA. On that basis, denial of credit for belated Form No. 67 filing is described as unjustified, with the assessee entitled to the credit.</description>
    <language>en-us</language>
    <pubDate>Thu, 25 Jun 2026 00:00:00 +0530</pubDate>
    <lastBuildDate>Wed, 01 Jul 2026 08:47:54 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=909370" rel="self" type="application/rss+xml"/>
    <item>
      <title>2026 (7) TMI 44 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=794158</link>
      <description>Foreign tax credit under section 90 is discussed as not being denied solely because Form No. 67 was filed after the rule 128(9) due date. The text states that the delayed filing was treated as a procedural lapse, not a substantive defect that extinguishes entitlement to credit. It further notes the view that rule 128(9) is directory and cannot override the statutory right to foreign tax credit under the Act and the applicable DTAA. On that basis, denial of credit for belated Form No. 67 filing is described as unjustified, with the assessee entitled to the credit.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Thu, 25 Jun 2026 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=794158</guid>
    </item>
  </channel>
</rss>