ITAT Mumbai: Delay in Filing Form 67 Not Fatal-Foreign Tax Credit Cannot Be Denied on Technical Grounds

Sachin Shrikant Khedekar Vs ACIT (ITAT Mumbai) ITAT Mumbai: Delay in Filing Form 67 Not Fatal-Foreign Tax Credit Cannot Be Denied on Technical Grounds The Mumbai ITAT held that foreign tax credit (FTC) under Section 90 cannot be denied merely due to delay in filing Form 67, as such requirement is procedural and directory in nature. In this case, the assessee had disclosed foreign income and claimed FTC in the return, but Form 67 was not filed within the prescribed time and was submitted later during rectification proceedings. The CPC and CIT(A) denied the credit solely on this ground. The Trib...