Foreign Tax Credit Allowed Despite Delays in Form 67 (Section 90)

Vikash Daga Vs ACIT (ITAT Delhi) Introduction: The ITAT Delhi ruling in the Vikash Daga vs ACIT case shines a light on the balance between procedural norms and substantive rights within the realm of taxation. The case addressed the denial of foreign tax credit due to the late submission of form 67, raising questions on whether procedural lapses can negate the substantive right to claim a foreign tax credit under Section 90 of the Income Tax Act. Analysis: In this case, the appellant, Vikash Daga, filed a return of income that included earnings made in the USA. He sought to claim a foreign tax ...