Delay in Filing of Form 67 not ground to Deny Relief u/s 90 of Income Tax: ITAT

The ITAT has ruled that a delay in filing Form 67 is not sufficient grounds to deny relief under Section 90 of the Income Tax Act. The case involved a taxpayer seeking relief under a Double Taxation Avoidance Agreement (DTAA) but faced a delay in submitting Form 67. The ITAT found that the delay should not automatically result in the denial of relief and emphasized that such reliefs should be granted based on the merits of the case. This ruling upholds the principle of equity and fairness in the tax system, ensuring that procedural delays do not unduly penalize taxpayers who have otherwise complied with the law. It provides important guidance on the application of tax relief provisions.