Foreign Tax Credit Cannot Be Denied Merely for Late Filing of Form 67: ITAT Delhi

Rahul Singhal Vs DCIT (ITAT Delhi) Core Issue: The core issue before the Tribunal was whether delayed filing of Form No. 67 under Rule 128(9) of the Income-tax Rules could defeat the assessee’s substantive claim for Foreign Tax Credit under sections 90/90A/91 read with applicable DTAAs, when such form was admittedly filed before completion of assessment proceedings. Facts of the Case: The assessee filed appeals for AYs 2017-18 and 2018-19 challenging denial of Foreign Tax Credit (FTC) and other additions. The appeals before the Tribunal were delayed by about 198/205 days owing to severe me...