https://www.taxtmi.com/caselaws?id=471133 Foreign tax credit under section 90/90A and an applicable tax treaty cannot be denied solely because Form No. 67 was furnished after the due date under section 139(1). Rule 128(9) prescribes the filing deadline for documentary proof of foreign taxes but does not provide that delayed filing forfeits the credit. The time requirement is therefore procedural and directory, while entitlement to credit remains substantive where the relevant foreign income has been taxed both in India and abroad. Delayed furnishing of Form No. 67 requires consequential recomputation of tax liability allowing the claimed credit. en-us Wed, 02 Apr 2025 00:00:00 +0530 Fri, 21 Aug 2026 20:33:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471133 Foreign tax credit under section 90/90A and an applicable tax treaty cannot be denied solely because Form No. 67 was furnished after the due date under section 139(1). Rule 128(9) prescribes the filing deadline for documentary proof of foreign taxes but does not provide that delayed filing forfeits the credit. The time requirement is therefore procedural and directory, while entitlement to credit remains substantive where the relevant foreign income has been taxed both in India and abroad. Delayed furnishing of Form No. 67 requires consequential recomputation of tax liability allowing the claimed credit. Case-Laws Income Tax Wed, 02 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471133