CIT (A) dismissed the appeal holding that there was a delay in filing of Form-67 and as per sub-Rule 9 of Rule 128 of the Income Tax Rules, 1962 it was mandatory, ignoring the judgment pronounced by ...
Conclusion: Despite late filing of Form 67, assessee deserved the credit for taxes paid in Nepal since the provisions of DTAA (in this case DTAA with Nepal) had an overriding effect over other ...