Late Form 67 Filing Ignored Because FTC Is a Vested Treaty Right

Mekala Rakesh Reddy Vs DCIT (ITAT Hyderabad)

DTAA Overrides Rule 128: FTC Allowed Despite Late Form 67 Filing-Delay in Form 67 Is Only Procedural- CPC Has No Power to Deny FTC for Technical Lapse

The Hyderabad ‘A’ Bench of the ITAT, in Mekala Rakesh Reddy vs DCIT (ITA Nos. 1429 & 1430/Hyd/2025, AYs 2021-22 & 2023-24), held that mere delay in filing Form 67 cannot be a ground to deny Foreign Tax Credit (FTC

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