Rule 128(9) Doesn't Mandate Disallowance of Foreign Tax Credit for Late Form No. 67; DTAA Takes Precedence.

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....Denial of Foreign Tax Credit (FTC) - (i) Rule 128(9) of the Rules does not provide for disallowance of FTC in case of delay in filing Form No. 67; (ii) filing for Form No. 67 is not mandatory but a directory requirement and (iii) DTAA overrides the provision of the Act and the rules cannot be contrary to the Act. - credit allowed - AT....