Tribunal held that filing of Form 67 is a procedural/ directory requirement and is not a mandatory requirement. Further, violation of procedural norms would not extinguish the substantive right of claiming credit of foreign tax credit of the Assessee. While holding so, the Tribunal observed that, if the intention of the legislature was to deny foreign tax credit, either the Act or the Rules would have specifically provided that credit would not be allowed if Form 67 is not filed within the prescribed due date. Such language is however not used in Rule 128(9) of the Rules. (AY. 2018-19, 2019-20)