Form 67 Filing: Directory, Not Mandatory, for Foreign Tax Credit Claims; Substantive Rights Upheld.

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Full Text of the Document

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....Entitlement to foreign tax credit - The Tribunal concludes that the filing of Form 67 is a procedural requirement and should be construed as directory rather than mandatory. It emphasizes that the violation of procedural norms does not extinguish the substantive right of claiming the foreign tax credit. - The Tribunal directs the Assessing Officer to grant the foreign tax credit to the assessee, based on its interpretation of the relevant provisions and judicial precedents.....