https://www.taxtmi.com/caselaws?id=794923 Foreign tax credit under Sections 90/90A of the Income-tax Act, 1961 should not be denied during processing under Section 143(1) merely because Form No. 67 was filed after the prescribed date. The approach discussed treats Rule 128(9) of the Income-tax Rules, 1962 as directory rather than mandatory, making the filing requirement procedural. Where the applicable DTAA grants credit for taxes paid overseas, that substantive relief should not be defeated solely by delayed procedural compliance. Accordingly, denial of the credit on this ground was considered unsustainable, and the credit was to be granted. en-us Fri, 10 Jul 2026 00:00:00 +0530 Tue, 14 Jul 2026 08:26:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794923 Foreign tax credit under Sections 90/90A of the Income-tax Act, 1961 should not be denied during processing under Section 143(1) merely because Form No. 67 was filed after the prescribed date. The approach discussed treats Rule 128(9) of the Income-tax Rules, 1962 as directory rather than mandatory, making the filing requirement procedural. Where the applicable DTAA grants credit for taxes paid overseas, that substantive relief should not be defeated solely by delayed procedural compliance. Accordingly, denial of the credit on this ground was considered unsustainable, and the credit was to be granted. Case-Laws Income Tax Fri, 10 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794923