Section 90 Relief Overrides Technical Delay in Form 67

Soumik Chatterjee Vs ITO (ITAT Kolkata) Substance Over Procedure—FTC Can’t Be Denied for Technical Delay- Foreign Tax Credit Allowed Despite Delayed Form 67 Kolkata ITAT ‘SMC’ Bench in Soumik Chatterjee vs ITO, Ward-33(2), Kolkata (ITA No.1508/Kol/2025, AY 2024-25, order dated 23-12-2025) allowed the assessee’s appeal and directed grant of foreign tax credit (FTC), holding that mere delay in filing Form 67 cannot be a ground to deny relief u/s 90/90A Assessee filed return on 31-07-2024, which was later revised on 28-08-2024. He claimed foreign tax credit relating to income accrued i...