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    <title>2025 (6) TMI 2142 - ITAT VISAKHAPATNAM</title>
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    <description>Delayed filing of Form No. 67 does not, by itself, disentitle an assessee from claiming Foreign Tax Credit under Section 90 of the Income-tax Act, 1961. Rule 128(9), as substituted with effect from 1 April 2022, prescribes the time and manner for furnishing the form but does not expressly mandate denial of credit solely for late filing. The amendment and its Explanatory Memorandum clarify that claims furnished during financial year 2022-23 may be allowed even when filed belatedly. Article 24 of the India-UK Double Taxation Avoidance Agreement also permits credit for taxes paid in the other country. The clarification is stated to operate retrospectively, including where Form No. 67 is filed before rectification.</description>
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      <description>Delayed filing of Form No. 67 does not, by itself, disentitle an assessee from claiming Foreign Tax Credit under Section 90 of the Income-tax Act, 1961. Rule 128(9), as substituted with effect from 1 April 2022, prescribes the time and manner for furnishing the form but does not expressly mandate denial of credit solely for late filing. The amendment and its Explanatory Memorandum clarify that claims furnished during financial year 2022-23 may be allowed even when filed belatedly. Article 24 of the India-UK Double Taxation Avoidance Agreement also permits credit for taxes paid in the other country. The clarification is stated to operate retrospectively, including where Form No. 67 is filed before rectification.</description>
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