Denial of Foreign Tax Credit due to late Form 67 filing deemed procedural, not mandatory. Assessee's appeal allowed.

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....The Appellate Tribunal (ITAT) considered the denial of Foreign Tax Credit (FTC) u/s late filing of Form 67. The assessee argued that Form 67 filing is procedural, not mandatory. ITAT held that Form 67 filing is directory, not mandatory, and non-compliance does not affect substantive rights. Orders below were set aside, directing the Assessing Officer to verify FTC claim upon accepting Form 67. The appeal of the assessee was allowed.....