FTC Claim Not Denied Despite Delay as Filing of Form 67 Held Directory, Not Mandatory: ITAT

The ITAT (Income Tax Appellate Tribunal) has ruled that an FTC (Foreign Tax Credit) claim is "not denied despite delay" as "filing of Form 67 held directory, not mandatory." Form 67 is required to claim foreign tax credit. This important decision provides relief to taxpayers who might have delayed in filing the specific form. The tribunal distinguished between mandatory and directory provisions, holding that while Form 67 is for procedural compliance, its delayed filing does not automatically invalidate the substantive right to claim FTC, especially if the underlying foreign tax payment is verifiable.