https://www.taxtmi.com/caselaws?id=796500 Rectification under section 254(2) extends to patent omissions and manifest inconsistencies, not a review on merits. Where an order records material on residential status and consequential foreign income but leaves those grounds undecided, and gives inconsistent foreign-tax-credit directions, the issues may be restored for fresh adjudication. Residential status is central to determining whether foreign income is chargeable in India and the eligible credit. Foreign tax credit cannot be denied solely because Form No. 67 was filed with a belated return before processing; the filing requirement is treated as directory, with Rule 128(9)'s amendment regarded as clarificatory. Eligible credit requires re-examination after determining residential status and taxable income. en-us Fri, 30 Jan 2026 00:00:00 +0530 Thu, 06 Aug 2026 09:11:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796500 Rectification under section 254(2) extends to patent omissions and manifest inconsistencies, not a review on merits. Where an order records material on residential status and consequential foreign income but leaves those grounds undecided, and gives inconsistent foreign-tax-credit directions, the issues may be restored for fresh adjudication. Residential status is central to determining whether foreign income is chargeable in India and the eligible credit. Foreign tax credit cannot be denied solely because Form No. 67 was filed with a belated return before processing; the filing requirement is treated as directory, with Rule 128(9)'s amendment regarded as clarificatory. Eligible credit requires re-examination after determining residential status and taxable income. Case-Laws Income Tax Fri, 30 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796500