Case Law Analysis
|Income Tax Appellate Tribunal
Foreign Tax Credit | Late Filing of Form 67 Does Not Bar Claim Under Sections 90/90A: ITAT Delhi
The ITAT Delhi has ruled that failure to file Form 67 by the due date under Section 139(1) is a procedural lapse, not a substantive bar to claiming Foreign Tax Credit. This decision affirms that Rule 128(9) is directory, not mandatory, protecting taxpayers who meet all other eligibility criteria despite technical delays.