FTC Cannot Be Denied If Form 67 Filed late but Before Assessment Completion

Joel Eliah Pusanur Vs DCIT (ITAT Delhi) Foreign Tax Credit Allowed Despite Delay in Filing Form 67; ITAT: Delay in Filing Form 67 is Procedural, Not Fatal to FTC Claim; Form 67 Filed Late Still Valid – ITAT Delhi Allows FTC to Non-Resident Assessee Assessee, a non-resident, filed return declaring ₹1.28 crore & claimed foreign tax credit (FTC) of ₹12.38 lakh u/s 90/90A. CPC denied the claim as Form 67 was filed belatedly (on 19.04.2021) & raised tax demand. Rectification u/s 154 was rejected, & CIT(A) confirmed the disallowance. Before Tribunal, Assessee argued that Form 67 wa...