https://www.taxtmi.com/caselaws?id=795990 Foreign tax credit under Section 90(2) and the applicable tax treaty cannot be denied solely because Form No. 67 was filed after the prescribed time. Rule 128 and Form No. 67 provide a procedural framework for claiming and verifying relief, while Rule 128(9) does not expressly provide for forfeiture due to delayed filing. Where foreign tax payment, the identity of doubly taxed rental income, and corresponding Indian tax are verifiable, treaty relief remains available. Credit for French taxes paid on rental income is subject to verification and limited to Indian tax attributable to that doubly taxed income. Questions on Article 6 of the India-France treaty and "may be taxed" were left open. en-us Mon, 18 May 2026 00:00:00 +0530 Thu, 30 Jul 2026 08:52:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795990 Foreign tax credit under Section 90(2) and the applicable tax treaty cannot be denied solely because Form No. 67 was filed after the prescribed time. Rule 128 and Form No. 67 provide a procedural framework for claiming and verifying relief, while Rule 128(9) does not expressly provide for forfeiture due to delayed filing. Where foreign tax payment, the identity of doubly taxed rental income, and corresponding Indian tax are verifiable, treaty relief remains available. Credit for French taxes paid on rental income is subject to verification and limited to Indian tax attributable to that doubly taxed income. Questions on Article 6 of the India-France treaty and "may be taxed" were left open. Case-Laws Income Tax Mon, 18 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795990