FTC cannot be denied

The Kolkata Bench of the Income Tax Appellate Tribunal held that Foreign Tax Credit (FTC) cannot be denied merely because Form No. 67 was filed after the due date prescribed under the Income-tax Rules. 

The Tribunal reiterated that filing of Form No. 67 is a procedural requirement and cannot defeat the substantive right to claim FTC under Section 90 of the Income-tax Act and the applicable DTAA.