https://www.taxtmi.com/caselaws?id=800472 Foreign tax credit under Section 90 is substantive double-taxation relief and cannot be curtailed solely because the return or Form No. 67 was filed late. Rule 128 prescribes procedural and documentation requirements for claiming the credit, including filing Form No. 67, but its filing requirement is directory where the taxpayer's entitlement, credit quantum, and supporting compliance are undisputed. As subordinate legislation, Rule 128 cannot defeat the statutory entitlement to foreign tax credit merely due to delayed filing under Section 139(4) or delayed submission of Form No. 67. en-us Fri, 25 Sep 2026 00:00:00 +0530 Wed, 07 Oct 2026 08:26:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800472 Foreign tax credit under Section 90 is substantive double-taxation relief and cannot be curtailed solely because the return or Form No. 67 was filed late. Rule 128 prescribes procedural and documentation requirements for claiming the credit, including filing Form No. 67, but its filing requirement is directory where the taxpayer's entitlement, credit quantum, and supporting compliance are undisputed. As subordinate legislation, Rule 128 cannot defeat the statutory entitlement to foreign tax credit merely due to delayed filing under Section 139(4) or delayed submission of Form No. 67. Case-Laws Income Tax Fri, 25 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800472