Denial of FTC claim due to delay in furnishing Form No. 67 unjustified: ITAT Delhi

Avik Anup Prabhu Osho Drive Vs DCIT (ITAT Delhi) ITAT Delhi held that Rule 128(9) nowhere debars claim of Foreign Tax Credit on account of delay in furnishing Form No. 67. The provisions contained under Rule 128(9) are directory and accordingly, allowed the credit of FTC. Facts- The assessee is a resident and filed his return of income originally u/s. 139(1) of the Act. Subsequently, the assessee filed a revised return of income claiming Foreign Tax Credit amounting to Rs. 49,54,248/- alongwith Form No. 67. While processing the return of income of the assessee, the CPC disallowed assessee’s ...