Assessee, a salaried employee, claimed foreign tax credit (FTC) while filing return of income but had not filed Form 67 before due date of filing of return under section 139(1) as prescribed under rule 128(9).  Assessee realized filing of Form 67 only after scrutiny proceedings were initiated by Assessing Officer and filed same with a delay of more than two years.  Assessing Officer invoked provision of rule 128(9) and disallowed FTC. The  Assessee contended that Form 67 was not filed by its tax consultant due to oversight and same was to be considered as technical mistake. Held  that since assessee filed Form 67 after a delay of two years without any valid and reasonable cause, Assessing Officer was justified in disallowing FTC claimed by assessee.  Filling of statement in Form 67 on or before due date specified for furnishing return of income under section 139(1) is mandatory in nature and not directory.  (AY. 2018-19)