FTC Disallowance for Late Form 67: Rule 128(9) Must Align with Act and DTAA for Fairness.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Disallowance of Foreign Tax Credit (FTC) - delay in filing Form 67 - Rule 128(9) of the Rules has to be read down in conformity thereof. Rule 128(9) of the Rules cannot be read in isolation. Rules must be read in the context of the Act and the DTAA impacting the rights, liabilities and disabilities of the parties. - AT....