No denial of FTC claim due to procedural delay in filing Form 67

Neetu Agarwal Vs ITO (ITAT Kolkata)

Conclusion: Denying of FTC claim due to procedural delay in filing Form 67 was not justified as the objective of the Article 23 of the DTAA and section 90 to mitigate double taxation which should not be compromised by procedural technicalities when substantive compliance was evident.

Held: Assessee was a resident individual who filed her income tax return for the financial year 2020-2021. She discharged her tax liability by virtue of tax deducted at source (TDS), self-assessment tax, and Foreign Tax Credit

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