Foreign Tax Credit should not be disallowed for mere late filing of Form 67

Deepak Shimoga Padmaraju Vs The Asst. Director of Income Tax (ITAT Bangalore) The case of Deepak Shimoga Padmaraju Vs The Assistant Director of Income Tax pertains to the denial of Foreign Tax Credit (FTC) by the Centralized Processing Centre (CPC) in Bangalore for the Assessment Year (AY) 2021-22. The denial was based on the late filing of Form 67, a procedural requirement under Rule 128(9) of the Income Tax Rules, 1962. The assessee, who earned income in Germany, claimed an FTC of ₹5,93,444 but filed Form 67 after the return filing deadline. Despite arguing that relief under the Double Tax...