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    <title>2026 (8) TMI 1422 - ITAT BANGALORE</title>
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    <description>Foreign Tax Credit should not be denied solely because Form No. 67 was furnished after the return-filing due date under Rule 128(9). Although the rule required timely filing for the relevant assessment year, it did not prescribe denial of credit as the consequence of delay. The later extension of the filing period and treatment of the requirement as directory support allowing substantive credit where foreign income was offered to tax in India and Form No. 67 with foreign-tax supporting documents was available before processing. The Foreign Tax Credit claim must therefore be examined on merits after accepting the form and related documents, while providing a reasonable hearing opportunity.</description>
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      <link>https://www.taxtmi.com/caselaws?id=797548</link>
      <description>Foreign Tax Credit should not be denied solely because Form No. 67 was furnished after the return-filing due date under Rule 128(9). Although the rule required timely filing for the relevant assessment year, it did not prescribe denial of credit as the consequence of delay. The later extension of the filing period and treatment of the requirement as directory support allowing substantive credit where foreign income was offered to tax in India and Form No. 67 with foreign-tax supporting documents was available before processing. The Foreign Tax Credit claim must therefore be examined on merits after accepting the form and related documents, while providing a reasonable hearing opportunity.</description>
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