https://www.taxtmi.com/caselaws?id=471230 Foreign tax credit for Australian taxes paid on income also taxed in India remains available despite delayed filing and verification of Form 67. Section 90 and Article 15 of the India-Australia tax treaty protect against double taxation, while Rule 128(9) prescribes the filing timeline without providing that delay forfeits credit. Form 67 filing is therefore procedural and directory where foreign tax was paid, corresponding income was taxed in India, and delay arose from technical verification difficulties and travel restrictions. Denial solely for late filing would defeat the substantive treaty entitlement and cause double taxation. en-us Tue, 06 Jan 2026 00:00:00 +0530 Tue, 25 Aug 2026 18:57:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471230 Foreign tax credit for Australian taxes paid on income also taxed in India remains available despite delayed filing and verification of Form 67. Section 90 and Article 15 of the India-Australia tax treaty protect against double taxation, while Rule 128(9) prescribes the filing timeline without providing that delay forfeits credit. Form 67 filing is therefore procedural and directory where foreign tax was paid, corresponding income was taxed in India, and delay arose from technical verification difficulties and travel restrictions. Denial solely for late filing would defeat the substantive treaty entitlement and cause double taxation. Case-Laws Income Tax Tue, 06 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471230