ITAT Pune Allows Foreign Tax Credit Despite Delayed Form 67 Filing

Vipul Chandrakant Sawalwade Vs ITO (ITAT Pune)

In a recent ruling, the Income Tax Appellate Tribunal (ITAT) Pune has delivered a significant decision concerning the admissibility of Foreign Tax Credit (FTC) even when Form 67, a crucial document for claiming such credit, is filed belatedly. The Tribunal also addressed the applicable tax rate for dividend income received from a US-based company, emphasizing the primacy of Double Taxation Avoidance Agreements (DTAAs) over domestic tax rates.

The case, Vipul Chandrakant Sawalwade Vs. ITO, involved an individual assessee

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