Taxpayer's Right to Foreign Tax Credit Upheld u/s 90 Despite Delayed Form Submission. Authorities Lacked Justification.

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....Relief of foreign tax credit u/s 90 - non compliance of procedural requirement - As the assessee has vested right to claim the FTC under the tax treaty and the same cannot be disallowed for mere delay in compliance of a procedural provision. - there were no reasons with the tax authorities for making disallowance when the said Form 67 was very much available with the AO at the time of framing the assessment order. - AT....