Foreign Tax Credit Claim Valid Despite Delay in Filing Form No. 67, Procedural Delays Shouldn't Affect Substantive Rights.

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....Eligibility of Foreign tax credit - delay in compliance of a procedural provision - delay in filing Form No.67 - Assessee has vested right to claim the FTC under the tax treaty, the same cannot be disallowed for mere delay in compliance of a procedural provision, that is ‘delay in filing Form No.67’. - AT....