ITAT Hyderabad: Foreign Tax Credit Cannot Be Denied for Delay in Filing Form 67; Requirement Held Directory

Sucharitha Reddy Mettu Vs ITO (ITAT Hyderabad) ITAT Hyderabad: Foreign Tax Credit Cannot Be Denied for Delay in Filing Form 67; Requirement Held Directory In this case, the assessee, an individual with foreign income from the USA, claimed foreign tax credit (FTC) under section 91 but filed Form 67 after the due date under section 139(1), though before completion of assessment. The AO denied FTC solely on the ground of delayed filing, and the CIT(A) upheld the denial. The ITAT held that filing of Form 67 under Rule 128 is directory and not mandatory, and if the form is furnished before completi...