https://www.taxtmi.com/caselaws?id=797370 Foreign Tax Credit arises substantively under Section 90 and applicable double-taxation avoidance arrangements, while Rule 128 governs the procedural documentation for claiming it. Delayed furnishing of Form No. 67 does not itself forfeit credit because Rule 128(9) prescribes no consequence of denial for late filing. Where foreign income is taxed in India, foreign tax has been paid, and Form No. 67 with supporting evidence is furnished, procedural delay should not defeat relief and cause double taxation. The condonation mechanism does not limit appellate relief where substantive conditions are satisfied. Credit must be examined on merits, including verification of foreign-tax payment and absence of a foreign refund. en-us Wed, 15 Jul 2026 00:00:00 +0530 Fri, 21 Aug 2026 08:28:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797370 Foreign Tax Credit arises substantively under Section 90 and applicable double-taxation avoidance arrangements, while Rule 128 governs the procedural documentation for claiming it. Delayed furnishing of Form No. 67 does not itself forfeit credit because Rule 128(9) prescribes no consequence of denial for late filing. Where foreign income is taxed in India, foreign tax has been paid, and Form No. 67 with supporting evidence is furnished, procedural delay should not defeat relief and cause double taxation. The condonation mechanism does not limit appellate relief where substantive conditions are satisfied. Credit must be examined on merits, including verification of foreign-tax payment and absence of a foreign refund. Case-Laws Income Tax Wed, 15 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797370