https://www.taxtmi.com/caselaws?id=794659 Belated filing of Form 67 did not justify denial of Foreign Tax Credit where the credit was already claimed in the return and the delay was explained by pandemic-related disruption. The Tribunal treated Rule 128 as directory, not mandatory, and held that DTAA benefits cannot be defeated by a procedural lapse. Rectification under section 154 was also maintainable because the credit was otherwise apparent from the record and the denial rested only on an unsustainable procedural objection. The assessee was therefore entitled to the credit, and the assessing authority was directed to grant it. en-us Mon, 08 Jun 2026 00:00:00 +0530 Thu, 09 Jul 2026 08:35:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794659 Belated filing of Form 67 did not justify denial of Foreign Tax Credit where the credit was already claimed in the return and the delay was explained by pandemic-related disruption. The Tribunal treated Rule 128 as directory, not mandatory, and held that DTAA benefits cannot be defeated by a procedural lapse. Rectification under section 154 was also maintainable because the credit was otherwise apparent from the record and the denial rested only on an unsustainable procedural objection. The assessee was therefore entitled to the credit, and the assessing authority was directed to grant it. Case-Laws Income Tax Mon, 08 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794659