Chennai ITAT Grants Full Foreign Tax Credit Despite Lower FTC Claim in Form 67 – Procedural Lapse Cannot Defeat Substantive Relief

Shrinivasan Ranganathan Vs ACIT (ITAT Chennai) The Chennai ITAT held that a lower Foreign Tax Credit (FTC) claim made in Form 67 cannot permanently disentitle an assessee from claiming the correct FTC amount when the relevant foreign tax payment details are already on record. The Tribunal observed that delay in filing or mistakes in Form 67 are merely procedural lapses and cannot override substantive relief available under sections 90/91 of the Act. In this case, the assessee originally claimed FTC of ₹8.70 crore in Form 67 filed along with the belated return. During scrutiny, additional LTC...