Delhi HC Allows Foreign Tax Credit Despite Delay in Filing Form 67

Real Time Data Services Private Limited Vs PCIT (Delhi High Court)

In Real Time Data Services Private Limited Vs PCIT, the Delhi High Court decided multiple writ petitions involving a common question of law concerning delay in filing Form No. 67 under Rule 128 of the Income Tax Rules, 1962, and denial of Foreign Tax Credit (FTC). The facts of W.P.(C) 959/2024 for Assessment Year 2020–21 were considered.

The petitioner had failed to file Form No. 67 within the prescribed time under Section 139 of the Income Tax Act, 1961. The omission was discovered only af

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