https://www.taxtmi.com/caselaws?id=794414 Salary received for services rendered in Australia was treated as taxable in Australia under Article 15 of the India-Australia DTAA, so the income was not chargeable to tax in India. The delayed filing of Form 67 under Rule 128(9) was not the core issue; the decisive point was that the salary itself fell outside Indian taxation because it arose from services performed in Australia. As a result, the foreign tax credit claimed for Australian tax did not survive once the income was excluded from India's tax base, and the credit was disallowed. en-us Tue, 30 Jun 2026 00:00:00 +0530 Sat, 04 Jul 2026 08:15:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794414 Salary received for services rendered in Australia was treated as taxable in Australia under Article 15 of the India-Australia DTAA, so the income was not chargeable to tax in India. The delayed filing of Form 67 under Rule 128(9) was not the core issue; the decisive point was that the salary itself fell outside Indian taxation because it arose from services performed in Australia. As a result, the foreign tax credit claimed for Australian tax did not survive once the income was excluded from India's tax base, and the credit was disallowed. Case-Laws Income Tax Tue, 30 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794414