Delay in Form 67 filing can't deny foreign tax credit under DTAA.

The assessee's claim for foreign tax credit under Section 90 was allowed despite a delay in filing Form No. 67 after the due date for filing the return under Section 139(1). The Income Tax Appellate Tribunal (ITAT) ruled that the delay in filing Form 67 cannot deny the right to claim foreign tax credit under the Double Taxation Avoidance Agreement (DTAA). Citing the Chiragkumar Nandalal Makadia case, the ITAT noted that Rule 128, which requires Form 67 to be filed before the return, is procedural, and non-compliance should not lead to the denial of foreign tax credit. The assessee's appeal was allowed. .....

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