Tribunal held that filing of Form No. 67 is not mandatory, but it is a directory requirement, and mere delay in filing Form No. 67 as per provisions of Rule 128(9) will not preclude assessee from claiming the benefit of foreign tax credit in respect of tax paid outside India. FTC is assessee’s vested right as per DTAA read with section 90, and the same cannot be disallowed for non-compliance with the procedural requirement. (AY. 2020-21)