Denial of Foreign Tax Credit due to late Form 67 filing - procedural or mandatory? ITAT held filing as procedural, not mandatory.

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....The Appellate Tribunal considered the denial of Foreign Tax Credit (FTC) due to late filing of Form 67. The return of income for AY 2021-22 was filed on 13.10.2021, with Form 67 submitted on 25.01.2022 and a rectified return on 04.09.2022. The Tribunal held that Form 67 filing is procedural, not mandatory, and non-compliance does not affect the substantive right to claim. Therefore, the grounds raised by the appellant were allowed.....