Income Tax Rule 128 for claiming foreign tax credit is directory in nature: ITAT Pune

Akshay Rangroji Umale Vs DCIT (ITAT Pune) ITAT Pune addressed the appeal in the case of Akshay Rangroji Umale Vs DCIT concerning the denial of Foreign Tax Credit (FTC) due to delayed filing of Form 67. The appellant, a resident Indian, reported global income, including salary earned in the USA, which was subject to tax both in India and the USA. To claim relief under the Indo-USA Double Tax Avoidance Agreement (DTAA), the appellant filed Form 67 belatedly after the due date specified under Section 139(1) of the Income Tax Act, 1961. This delay led the CPC to reject the FTC claim, a decision up...