ITAT allows Foreign Tax Credit despite Delayed Filing of Form No. 67, Rules Income Tax Rule 128(9) Directory, not Mandatory

The Income Tax Appellate Tribunal (ITAT) ruled that the delayed filing of Form No. 67 should not disqualify a taxpayer from claiming Foreign Tax Credit (FTC). The tribunal held that Rule 128(9) of the Income Tax Rules, which governs the timeline for submitting Form No. 67, is directory and not mandatory. This ruling is a significant relief for taxpayers who might miss filing deadlines due to various reasons but still wish to claim FTC. The decision underscores the ITAT's flexible and taxpayer-friendly approach in interpreting tax laws, particularly in cases involving international taxation.