https://www.taxtmi.com/caselaws?id=794898 Foreign tax credit under Section 90 should not be denied solely because Form No. 67 was filed after the time prescribed by Rule 128(9). The analysis treats the relevant DTAA provisions, where more beneficial, as prevailing over the Act and subordinate rules. Rule 128(9) prescribes the timing and manner of filing but does not expressly provide that delayed filing extinguishes the substantive credit entitlement. The filing requirement is therefore characterised as procedural and directory, while credit for foreign taxes paid abroad is treated as a vested right. On this reasoning, delayed filing of Form No. 67 does not by itself justify denial of foreign tax credit. en-us Fri, 12 Jun 2026 00:00:00 +0530 Tue, 14 Jul 2026 08:26:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794898 Foreign tax credit under Section 90 should not be denied solely because Form No. 67 was filed after the time prescribed by Rule 128(9). The analysis treats the relevant DTAA provisions, where more beneficial, as prevailing over the Act and subordinate rules. Rule 128(9) prescribes the timing and manner of filing but does not expressly provide that delayed filing extinguishes the substantive credit entitlement. The filing requirement is therefore characterised as procedural and directory, while credit for foreign taxes paid abroad is treated as a vested right. On this reasoning, delayed filing of Form No. 67 does not by itself justify denial of foreign tax credit. Case-Laws Income Tax Fri, 12 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794898