Ms. Brinda Ramakrishna v. ITO
135 Taxmann.com 358Income Tax Appellate Tribunal2022#991 most cited
What is Ms. Brinda Ramakrishna v. ITO authority for?
The filing of Form 67 for claiming Foreign Tax Credit (FTC) is a directory requirement, not mandatory. Rule 128(9) does not provide for disallowance of FTC due to delay in filing this form. Double Taxation Avoidance Agreements (DTAAs) override domestic law.
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judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2022 to 2026.
Also referred to as
Ms. Brinda Ramakrishna v. ITO · Form 67 · Foreign Tax Credit · Rule 128(9) · DTAA · delay in filing · mandatory vs directory
Also reported as
193 ITD 840