Violation of procedural norm does not extinguish substantive right of claiming Foreign Tax credit

Sri. Sandeep Patwari Vs DCIT (ITAT Bangalore) Violation of procedural norm does not extinguish substantive right of claiming Foreign Tax credit (FTC) Assessee received 143(1) intimation wherein the foreign tax credit (FTC) of Rs.14,02,442 was not granted. Rectification application filed u/s 154 too did not allow the claim of the assessee. CIT(A) confirmed the 154 order holding that the assessee has not filed Form No.67 before the prescribed time limit. CIT(A) concluded that Form No.67 filed belatedly is non est in law and the provisions of Rule 128 of the I.T. Rules are mandatory in nature. Be...