2025 (6) TMI 307

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.... The only issue to be adjudicated in this case is whether the appellant company can be denied the benefit of the foreign tax credit by Ld. CPC where Form 67 was filed after the due date of filing of Return of Income. 2. The Ld. CPC and Ld. CIT(A) denied the benefit of Foreign Trade Credit (FTC) because they held that the Rule 128(9) is mandatory in nature and not directory and the Form 67 shall b....