Late Form 67 Filing Ignored Because FTC Is a Vested Treaty Right

Mekala Rakesh Reddy Vs DCIT (ITAT Hyderabad) DTAA Overrides Rule 128: FTC Allowed Despite Late Form 67 Filing-Delay in Form 67 Is Only Procedural- CPC Has No Power to Deny FTC for Technical Lapse The Hyderabad ‘A’ Bench of the ITAT, in Mekala Rakesh Reddy vs DCIT (ITA Nos. 1429 & 1430/Hyd/2025, AYs 2021-22 & 2023-24), held that mere delay in filing Form 67 cannot be a ground to deny Foreign Tax Credit (FTC) where the foreign income has been duly offered to tax in India and tax has already been paid abroad. The Assessee had earned salary income from the UK, disclosed the same in the...