FTC Claim Cannot Be Denied for Late Submission as Form 67 Was Not Mandatory

Basavalinga Sadasivaiah Ajaikumar Vs ADIT (ITAT Bangalore) Conclusion: Foreign Tax Credit (FTC) should not be denied just because of late filing of Form 67 as Form 67 was directory rule, not mandatory under Rule 128. Held: Assessee filed his original income tax return on 31-08-2019 and revised the return on 19-06-2020. He submitted Form 67 to claim the foreign tax credit but AO denied the FTC claim due to the late filing of Form 67. AO issued intimation notice to assessee generated under Section 143(1). On appeal, CIT (Appeals) dismissed assessee’s claim. Aggrieved by CIT(A) order, assessee ...