Assessee earned foreign business income on which tax was paid in Nepal. Assessee filed its return claiming FTC. AO denied the claim on the ground that Form No. 67 was filed belatedly. Held, assessee deserved credit for taxes paid in Nepal since provisions of India-Nepal DTAA, which provides for eliminating double taxation of income, have an overriding effect over other provisions of the Act. Therefore, it would be entitled to FTC even if Form No. 67 was filed belatedly (AY. 2021-22)