“foreign tax credit”

International TaxSection 90 / Rule 128Section 90 / Rule 128571 judgments

The decision most relied on for foreign tax credit is Chandra Kishore Jha v. Mahavir Prasad (8 SCC 266), cited in 163 judgments on BharatTax.

Leading authorities on foreign tax credit

Chandra Kishore Jha v. Mahavir Prasad

8 SCC 266 · 1999 · Supreme Court

163

citing judgments

If a statute or law prescribes that a thing must be done in a particular manner, then it must be done in that manner alone and in no other way. This principle mandates strict adherence to statutory procedures.

Wipro Ltd. v. DCIT

382 ITR 179 · 2016 · High Court

122

citing judgments

Foreign Tax Credit (FTC) is allowable even if no tax is paid in India on the corresponding income due to deductions under sections 10A or 10AA, or losses in other units. The scope of income eligible for deduction under Section 10AA includes interest on deposits and realized gains on forward contracts.

Ms. Brinda Ramakrishna v. ITO

135 Taxmann.com 358 · 2022 · ITAT

109

citing judgments

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.

CIT v. ACE Multitaxes Systems (P.) Ltd.

317 ITR 207 · 2009 · High Court

107

citing judgments

For claiming relief under Chapter VI-A deductions like Section 80IB or 80IA, the audit report in Form 10CCB is not mandatory to be filed with the return of income, but can be submitted before the assessment is completed.

Sambhaji and Others v. Gangabai and Others

17 SCC 117 · 2008 · Supreme Court

citing judgments

Procedural law serves as an aid to justice, not an obstruction, and should not ordinarily be construed as mandatory; it is subservient to substantive justice.

42 Hertz Software India (P.) Ltd. v. ACIT

139 Taxmann.com 448 · 2022 · ITAT

citing judgments

The claim for Foreign Tax Credit cannot be denied solely due to a delay in filing Form-67, as the requirement for filing Form-67 under Rule 128(9) is considered directory and not mandatory. The provisions of a Double Taxation Avoidance Agreement (DTAA) prevail over the Income-tax Act, 1961.

Duraiswamy Kumaraswamy v. PCIT

460 ITR 615 · 2024 · High Court

citing judgments

An assessee's claim for Foreign Tax Credit (FTC) cannot be rejected merely because Form 67 was filed after the due date under section 139(1), provided it is filed before the completion of assessment proceedings.

Sonakshi Sinha v. CIT

142 Taxmann.com 414 · 2022 · ITAT

citing judgments

The requirement to file Form 67 by the due date for claiming foreign tax credit is directory, not mandatory, if filed before the completion of assessment proceedings.

Judgments citing foreign tax credit

Preeti Das, Telangana vs. Income Tax Officer, Circle-12, Pune

In the result, the appeal of the assessee is allowed

ITA 2491/PUN/2024[2019-20]Status: DisposedITAT Pune21 Jan 2025AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Siddhesh ChauguleFor Respondent: Shri Arvind Desai

Section 139(1)Section 139(5)Section 154Section 90(2)

India-USA Treaty . However, the Form No.67 was filed by the appellant on 23.03.2020. The CPC, Bangalore, vide Intimation dated 18.02.2021 denied the Foreign Tax Credit claimed by the assessee at Rs.7,34.421/-, as Form No.67 was not filed within prescribed time. Against the said intimation, the assessee filed ... filed before the time limit specified u/s.139(1) of the Act and filing of Form No.67 is mandatory to claim the benefit of Foreign Tax Credit. 3 Preeti Das 4. Now the appellant is in appeal before the Tribunal challenging the order passed by ld. NFAC affirming the action

Hardik Hitesh Shah, Mumbai vs. Income Tax Officer, Mumbai

In the result, appeal of the assessee bearing ITA 3331/Mum/2024 is allowed

ITA 3331/MUM/2024[2018-19]Status: DisposedITAT Mumbai16 Jan 2025AY 2018-19

Bench: Shri Amarjit Singh & Shri Anikesh Banerjeehardik Hitesh Shah Vs The Income-Tax Officer, 702, 7Th Floor, A-Wing Ward 41(1)(1), Mumbai Veesita Residency, Azad Road, Kautilya Bhavan Andheri East, Mumbai-400 069 Bkc, Mumbai-400 051 Pan:Bjzps7889E Appellant Respondent

For Appellant: Shri Nikhil TiwariFor Respondent: Shri Hemanshu Joshi (SR. DR.)

Section 143Section 143(3)Section 234BSection 250Section 270ASection 271ASection 6

Further, in terms of the US assignment, the assessee has an agreement with the employer that any tax arising in India (after considering foreign tax credit) on US salary would be borne by the employer of the assessee. Therefore, upon realizing the inadvertent mistake, which was bonafide and unintentional errors

Excelsoft Technologies Limited, Mysore vs. DCIT, Circle-1(1), Mysore

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2191/BANG/2024[2020-21]Status: DisposedITAT Bangalore13 Jan 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadavassessment Year: 2020-21

For Appellant: Shri Bibhuti Ram Krishna, CAFor Respondent: Shri V. Parithivel, Jt.CIT (DR)(ITAT), Bengaluru

Section 115JSection 139(1)Section 143(1)Section 143(3)Section 154Section 90

preferred this appeal raising the following the two effective grounds of appeal:- Page 2 of 9 “2. Grounds relating to claim of Foreign Tax Credit: 2.1 The lower authorities have erred in not allowing relief under section 90 in respect of foreign taxes ... foreign taxes in the return of income nor in the application for rectification under section 154; (ii) not appreciating that not claiming foreign tax credit in the return of income was a bonafide mistake; (iii) not appreciating that there was no provision in the online application under section

Shilpa Prabhakar Kulkarni, Mumbai vs. DCIT, Circle 42(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 6144/MUM/2024[2020-21]Status: DisposedITAT Mumbai13 Jan 2025AY 2020-21

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Ms.Chandni Shah a/w Shri HardikNirmal andFor Respondent: Ms. Nidhi Agarwal (Sr. DR)

Section 139(1)Section 143(1)Section 234ASection 234BSection 234CSection 250Section 6Section 90

facts and contrary to the provisions of the law and accordingly, liable to be quashed. 2. Ground no. 2-Non-grant of Foreign Tax Credit On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in confirming the action ... denying/non-granting the foreign tax credit amounting to INR 19.96,823 as claimed by the Appellant in its Return of Income. 3. Ground no. 3-Impermissible adjustment made under section 143(1) of the Act On the facts and in the circumstances of the case

Deputy Commissioner of Income Tax, Vadodara vs. Jay Dushyant Patel, Vadodara

In the result, we find that Ld

ITA 981/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad09 Jan 2025AY 2021-22

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: Respondent by: Shri Virat Bhavsar, A.RFor Respondent: Shri Virat Bhavsar, A.R

Section 139(1)Section 139(4)Section 143(1)Section 90

circumstances of the case and in law, the Ld. Addl./JCIT(A) is justified in directing the Assessing Officer to allow Foreign Tax credit claimed u/s. 90 of the Act without appreciating the fat that the assessee has neither filed return of income nor Form No.67 within due date ... circumstances of the case and in law, the Ld. Addl. JCIT(A) is justified in directing the Assessing Officer to allow Foreign Tax Credit claimed u/s 90 of the Act, without appreciating the fact that the assessee has failed to adhere to the mandatory condition of filing of Form No.67

Deputy Commissioner of Income Tax, Vadodara vs. Jay Dushyant Patel, Vadodara

In the result, we find that Ld

ITA 980/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad09 Jan 2025AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: Respondent by: Shri Virat Bhavsar, A.RFor Respondent: Shri Virat Bhavsar, A.R

Section 139(1)Section 139(4)Section 143(1)Section 90

Smt. Maya Kapoor, Gurugram vs. Income Tax Officer, Ward-2(4), Gurgaon

Appeal is allowed for statistical purposes

ITA 4809/DEL/2024[2020-21]Status: DisposedITAT Delhi07 Jan 2025AY 2020-21

Bench: Sh. Satbeer Singh Godara

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Sh. Sanjay Kumar, Sr. DR

Section 139Section 143(1)Section 234ASection 90

234C of the Income Tax Act, 1961.” 4. It emerges during the course of hearing that the learned lower authorities have denied foreign tax credit benefit to the assessee for the sole reason that she could not file/upload the corresponding Form 67 on or before the prescribed “due” date

Ravinder Nath Goel, New Delhi vs. ACIT, Circle-47(1), New Delhi

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2473/DEL/2019[2015-16]Status: HeardITAT Delhi07 Jan 2025AY 2015-16

Bench: SHRI VIKAS AWASTHY (Judicial Member), DR. MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri Ashish Tripathi, Sr. DR

Section 143(1)Section 154Section 234ASection 89Section 90

amounting to Rs.4,92,346/-. The assessee also filed Form 67 declaring income from outside India amounting to Rs.22,35,787/- and claimed foreign tax credit outside India amounting to Rs.4,92,346. Thereafter, CPC has passed intimation order on 22.03.2022 disregarding the relief u/s 89 of the Act amounting

Vivek Singhal, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee is allowed

ITA 1606/BANG/2024[2017-18]Status: DisposedITAT Bangalore06 Jan 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Navaneeth .N. Kini, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 234B

assessee challenging the orders of the NFAC, Delhi dated 27/06/2024 in respect of the A.Y. 2017-18 on following grounds of appeal: “1. Foreign tax credit has been disallowed on the grounds that form 67 has not been filed within the due date. This requirement can never ... Without prejudice to the above contention, with the filing of form 67 on 05-Apr-2019 vide ack no. 461884540050419, disallowance of foreign tax credit holding that tiling of form 67 within the due date is a pre- condition for grant of foreign tax credit is not in line with

Vaibhav Singh, Jaipur vs. ITO 1(2), Jaipur

In the result, appeal of the assessee is allowed

ITA 1081/JPR/2024[AY2022-23]Status: DisposedITAT Jaipur02 Jan 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shailesh Mantri, C.AFor Respondent: Shr. Anup Singh, Addl.CIT a

Section 143(1)(a)Section 154Section 90

appeal was filed on 19.01.2023. The appellant has submitted that the delay in filing Form 67 does not result in disallowance of the Foreign Tax Credit as per IT Rules. The appellant has placed reliance is placed on following cases:- 5 Vaibhav Singh vs. ITO 1. Hon'ble ITAT BANGALORE ... manner so prescribed. Therefore, the reasoning given by the delay in filing Form 67 does not result in disallowance of the Foreign Tax Credit as per IT Rules is not tenable. Since the appellant has failed to file the Form 67, the AO, CPC has rightly disallowed the claim Foreign

Rishi Khare, Hyderabad vs. ITO., Ward-12(6), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 827/HYD/2024[2020-21]Status: DisposedITAT Hyderabad30 Dec 2024AY 2020-21

Bench: Shri Manjunatha G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.827/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2020-21) Rishi Khare Vs. Ito, Ward-12(6) Hyderabad Hyderabad [Pan : Amjpk4465G] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Pankaj Sancheti, Ar रधजस् व द्वधरध/Revenue By:: Shri R.Kumaran, Dr सुिवधई की तधरीख/Date Of Hearing: 18/12/2024 घोर्णध की तधरीख/Date Of 30/12/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 13.05.2024 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre, Delhi, Pertaining To A.Y.2020-21. 2. At The Outset, It Is Observed That The Appeal Has Been Filed With A Delay Of 45 Days. The Assessee Filed A Petition For Condonation Of Delay & Submitted That The Assessee Was Not Informed Of The Issuance Of The Order Dated 13.05.2024 By The Ld.Cit(A) & He Was Under The Genuine Belief That The Matter

For Appellant: Shri Pankaj Sancheti, ARFor Respondent: : Shri R.Kumaran, DR

Section 139(1)Section 139(5)Section 143(1)Section 90

Income tax Act, 1961 (“the Act”) was issued and determined the total tax payable at Rs.3,44,470/-, by denying Foreign Tax Credit (“FTC”) of Rs.2,37,156/- for non-submission of return of income along with Form 67 for claiming FTC in terms of section ... Rule 128(9). We find the learned CIT (A) NFAC upheld the action of the Assessing Officer in denying the relief for foreign tax credit, the reasons of which have already been reproduced in the preceding paragraph. We find an identical issue had come up before the Coordinate Bench

Loveen Babu Vuppala, Secunderabad vs. ITO., Ward-9(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1121/HYD/2024[2021-22]Status: DisposedITAT Hyderabad30 Dec 2024AY 2021-22

Bench: Shri Manjunatha G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.1121/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2021-22) Loveen Babu Vuppala Vs. Income Tax Officer Secunderabad Ward-9(1) [Pan : Alppv1796E] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Ms.Aluru V Sai Sudha, Ar रधजस् व द्वधरध/Revenue By:: Shri R.Kumaran, Dr सुिवधई की तधरीख/Date Of Hearing: 19/12/2024 घोर्णध की तधरीख/Date Of 30/12/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.08.2024 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], Kolkata, Pertaining To A.Y.2021-22 On The Following Grounds : 1. The Cit(A) Erred In Not Condoning The Delay & Not Admitting The Appeal 2. The Cit(A) Erred In Holding That There Was No Sufficient Cause For Condoning The Delay In Filing The Appeal

For Appellant: Ms.Aluru V Sai Sudha, ARFor Respondent: : Shri R.Kumaran, DR

Section 119(2)(b)Section 139(1)Section 143(1)Section 154Section 234A

considering of application for condonation of delay in filing the appeal 4. CIT(A) erred in upholding the intimation and denial of foreign tax credit by CPC 5. The order of the CIT(A) is in gross violation of principles of natural justice 6. CIT(A) erred in upholding ... employment, filed his return of income for the A.Y.2021-22 on 31.01.2022, declaring total income of Rs.3,18,99,930/- and also claimed foreign tax credit of Rs.67,29,287/- towards taxes paid on income earned from his employment from outside India. The AO/CPC processed the return of income filed

Sanjay Kumar, Uae vs. Int Tax Ward 4(2)(1), Mum, Mumbai

In the result, the appeal of appellant is allowed

ITA 3505/MUM/2024[AY 2016-17]Status: DisposedITAT Mumbai30 Dec 2024

Bench: Shri Narender Kumar Choudhryshri Omkareshwar Chidarasanjay Kumar, C/O Johnson & Johnson Pvt. Ltd. 501, Arena Spcaes, Off Jvlr Road, Behind Majas Depot Jogeshwari East Maharashtra ……………. Appellant Pan: Aazps9534Q V/S Income Tax Officer (It)– 4(2)(1), Room No.1916, 19Th Floor, Air India Building, Nariman Point ……………. Respondent Mumbai - 400021 Maharashtra

For Appellant: Ms. Riddhi JainFor Respondent: Shri Krishna Kumar (Sr.DR)

Section 143(3)Section 250Section 271(1)(c)Section 90

concerned broker of shares has reinvested the dividend received in the shares. Further, the dividend tax was also taxed in USA, 4 Foreign tax credit / relief under section 90 of the Act is available to the extent of Rs.1,53,630/- and the additional tax payable / paid ... relevant incomes and in such facts and circumstances, Hon’ble Supreme Court has confirmed penalty. But, in the impugned case, there is a foreign tax credit, the appellant immediately 5 admitted the mistake, the appellant’s status is Resident but not Ordinarily Resident with huge taxable income of Rs.5.65 crore

Biocon Biologics Limited, Bangalore vs. The Assistant Commissioner of Income Tax, Circle 2(1)(1), Bangalore

ITA 1590/BANG/2024[2020-21]Status: DisposedITAT Bangalore23 Dec 2024AY 2020-21

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadavit(Tp)A No.1590/Bang/2024

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru

Section 115JSection 143(3)Section 92Section 92C

TDS/TCS) even though the same are appearing in Form 26AS of both the entities (i.e., the Appellant and BRL). 8.5 in not granting Foreign Tax Credit ("FTC") of INR 2,87,674 claimed by the Appellant in the tax return for the subject AY. 8.6 in not granting the above

Prukalpa Sankar, Bangalore vs. Income Tax Officer, Ward 5(3)(5), Bengaluru

Appeal of the assessee is allowed for statistical purposes

ITA 2100/BANG/2024[2019-20]Status: DisposedITAT Bangalore16 Dec 2024AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Karanjot Singh K & Devashish JainFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 139(1)Section 143(1)Section 143(1)(a)Section 143(3)Section 154Section 90

assessee is that the learned CIT(A) erred in confirming the order of the Assessing Officer (AO) by denying the benefit of foreign tax credit (FTC) under section 90 read with Rule 128 of the Income Tax Rules. 3. The assessee, an individual deriving income under the head ‘salary ... global income of the assessee, including salary income earned from a Singapore-based company, was taxable in India. The assessee claimed a foreign tax credit of Rs. 56,867/- in the return of income filed under Section 139(1) of the Income Tax Act. However, form 67, required for claiming

Prukalpa Sankar, Bangalore vs. Income Tax Officer, Ward 5(3)(5), Bengaluru

Appeal of the assessee is allowed for statistical purposes

ITA 2099/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Dec 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Karanjot Singh K & Devashish JainFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 139(1)Section 143(1)Section 143(1)(a)Section 143(3)Section 154Section 90

Rahul Anand, Kolkata vs. A.D.I.T., CPC, Bangalore

The appeal of the assessee is allowed

ITA 1497/KOL/2024[2019-2020]Status: DisposedITAT Kolkata06 Dec 2024AY 2019-2020

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Year: 2019-20

For Appellant: Shri Rajat Agarwal, ARFor Respondent: Shri Supriya Pal, DR

Section 143(1)Section 154Section 250Section 295(1)Section 90

return. Here as per section 295(1) of the Act, CBDT has been given the power to prescribe the procedure for granting foreign tax credit and board does not have power to prescribe for disallowance of foreign tax credit. Rahul Anand; A.Y. 2019-20 (2) For that CIT (A) erred ... Income-tax rules, 1962, as it stood during the year under consideration, will not preclude the assessee from claiming the benefit of foreign tax credit in respect of taxes paid outside India. (4) For that Assistant Director of Income Tax, CPC, (in short "AO") and CIT (A) erred

Surrendra Kumar Goenka, Howrah vs. ADIT, CPC, Bengaluru / I.T.O., Ward 61(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1831/KOL/2024[2020-2021]Status: DisposedITAT Kolkata05 Dec 2024AY 2020-2021

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 139Section 139(1)Section 143(1)Section 234ASection 5Section 90

taxes have been paid in Netherlands for the salary income earned and received during said period. Hence, to avoid double taxation , a foreign tax credit amounting to INR 20,64,365/- had been claimed as per Article 23 of the India Netherlands Double Taxation Avoidance Agreement (DTAA) (attached at page ... statement in Form no. 67 along with supporting documents have been filed on 22nd February, 2021 for above stated foreign tax credit (attached at page no. 93 to 115) before filing revised tax return on 23rd February, 2021. vi) The assessee has a copy of his Employment letter in relation

Debanjan Chatterjee, Kolkata vs. D.D.I.T., CPC, Bengaluru, Bengalore

In the result, the appeal of the assessee is allowed

ITA 1959/KOL/2024[2021-2022]Status: DisposedITAT Kolkata02 Dec 2024AY 2021-2022

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 1959/Kol/2024 Assessment Year: 2021-2022 Debanjan Chatterjee,……..…………….…………Appellant C-3/14, East Enclave Cooperative Society, Rajarhat, Kolkata-700156 [Pan:Aezpc7707H] -Vs.- Deputy Director Of Income Tax,………………Respondent Cpc, Bengluru, Bangalore-560500 Appearances By: Shri Nilesh Kariya, A.R., Appeared On Behalf Of The Assessee Shri Sanjay Paul, Addl. Cit,Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 28, 2024 Date Of Pronouncing The Order: December 02, 2024 O R D E R

Section 139Section 139(4)Section 143(1)Section 154Section 90

Kingdom. The assessee also filed Form 67 (relating to filing a Statement of income from a country or specified territory outside India and Foreign Tax Credit) in support of its foreign tax credit. The reasons cited by the assessee for the delayed filing of income tax return was that ... these are being disposed as one as below. On perusal of the Rectification Order dated 24.02.2023, it is observed that the claim of foreign tax credit to the tune of Rs.37,79,568/- Under Section 90/90A of the IT Act was disallowed. It is claimed that inspite of filing

Kamlesh D Patel, Chegur, Rangareddy vs. ACIT, Circle-2(1)(1), Vadodara

In the result, the appeal filed by the Assessee is allowed for statistical purpose

ITA 1178/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad29 Nov 2024AY 2019-20

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 139(1)Section 154Section 68Section 90

exparte assessment order treating the agriculture income as unexplained cash credit u/s. 68 of the Act and also denied the claim of Foreign Tax Credit (hereinafter referred as FTC) relief u/s. 90 of the Act to the tune of Rs.10,35,734/- since Form No. 67 was not filed along ... assessment year. However, in the appellate proceedings, the assessee filed its written submission and pleaded that filing of Form No. 67 for claiming Foreign Tax Credit is only directory and not mandatory. Hence late filing of Form No. 67 on 24-03-2024 is not mandatory and the assessee should