https://www.taxtmi.com/caselaws?id=798885 Foreign Tax Credit under section 90 is substantive relief against double taxation, while Form No. 67 under Rule 128(9) serves a procedural function by providing implementation particulars. Delay in furnishing the form does not carry a prescribed forfeiture of an otherwise admissible credit, and the later extension of the filing time supports this procedural character. The administrative condonation mechanism under section 119(2)(b) does not restrict appellate relief where substantive eligibility is established. Foreign-tax payment must be verified, following which admissible credit should be allowed without requiring separate condonation solely for delayed Form No. 67. en-us Mon, 24 Aug 2026 00:00:00 +0530 Mon, 14 Sep 2026 08:32:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798885 Foreign Tax Credit under section 90 is substantive relief against double taxation, while Form No. 67 under Rule 128(9) serves a procedural function by providing implementation particulars. Delay in furnishing the form does not carry a prescribed forfeiture of an otherwise admissible credit, and the later extension of the filing time supports this procedural character. The administrative condonation mechanism under section 119(2)(b) does not restrict appellate relief where substantive eligibility is established. Foreign-tax payment must be verified, following which admissible credit should be allowed without requiring separate condonation solely for delayed Form No. 67. Case-Laws Income Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798885