https://www.taxtmi.com/caselaws?id=795062 Foreign Tax Credit cannot be denied solely because Form No. 67 was filed late where foreign taxes were otherwise paid. Rule 128(9) of the Income-tax Rules is treated as directory, not mandatory, because it prescribes no penalty or disallowance for delayed filing. The applicable Double Taxation Avoidance Agreement provision governing credit for foreign taxes paid prevails over this domestic procedural requirement. Accordingly, delayed compliance with the Form No. 67 filing requirement does not by itself defeat entitlement to Foreign Tax Credit. en-us Fri, 12 Jun 2026 00:00:00 +0530 Thu, 16 Jul 2026 09:07:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795062 Foreign Tax Credit cannot be denied solely because Form No. 67 was filed late where foreign taxes were otherwise paid. Rule 128(9) of the Income-tax Rules is treated as directory, not mandatory, because it prescribes no penalty or disallowance for delayed filing. The applicable Double Taxation Avoidance Agreement provision governing credit for foreign taxes paid prevails over this domestic procedural requirement. Accordingly, delayed compliance with the Form No. 67 filing requirement does not by itself defeat entitlement to Foreign Tax Credit. Case-Laws Income Tax Fri, 12 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795062