Foreign Tax Credit (FTC) Allowed Despite Delay in Filing Form No. 67

Nitin Khurana Vs ITO (ITAT Delhi) The Delhi Bench of the ITAT heard the appeal of individual for AY 2023‑24 against the order of CIT(A). The dispute arose from denial of Foreign Tax Credit (FTC) on foreign income due to a 9‑day delay in filing Form 67, which led CPC to disallow the claim and raise tax liability with interest. The assessee argued that filing Form 67 is procedural, not mandatory, and relied on judicial precedents including the Delhi High Court ruling in Real Time Data Services Pvt. Ltd. The Tribunal agreed, holding that a procedural lapse cannot extinguish a substantive righ...