https://www.taxtmi.com/caselaws?id=794528 Delayed filing of Form No. 67 under Rule 128 does not, by itself, disentitle an assessee from Foreign Tax Credit where the foreign tax paid and inclusion of the related income in India are undisputed. Rule 128 was treated as a procedural mechanism for furnishing particulars to verify the claim, not as the source of the substantive credit right under section 90 read with the treaty. Rigid insistence on the form's timing could not defeat relief against double taxation. The credit was therefore allowed, subject only to limited verification of the foreign tax paid. en-us Tue, 30 Jun 2026 00:00:00 +0530 Tue, 07 Jul 2026 08:39:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794528 Delayed filing of Form No. 67 under Rule 128 does not, by itself, disentitle an assessee from Foreign Tax Credit where the foreign tax paid and inclusion of the related income in India are undisputed. Rule 128 was treated as a procedural mechanism for furnishing particulars to verify the claim, not as the source of the substantive credit right under section 90 read with the treaty. Rigid insistence on the form's timing could not defeat relief against double taxation. The credit was therefore allowed, subject only to limited verification of the foreign tax paid. Case-Laws Income Tax Tue, 30 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794528