Foreign Tax Credit Claim Valid Despite Late Filing; Rule 128 is Procedural, Not Mandatory; Income Tax Act Prevails.

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....Denial of claim of Foreign Tax Credit (FTC) - Delay in filing of ITR - Rule 128 is only a procedural provision and not a mandatory provision and cannot override the provisions of the Act or the DTAA - Delay in filing the return and Form No.67 (i.e., beyond period under section 139(1) of the Act) is not fatal to the claim of FTC - AT....