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“foreign tax credit”

International TaxSection 90 / Rule 128Section 90 / Rule 128571 judgments

NITIN KHURANA,DELHI vs. ITO, DELHI

In the result, the appeal of the assessee is allowed

ITA 5264/DEL/2025[2023-24]Status: DisposedITAT Delhi18 Mar 2026AY 2023-24

Bench: Shri Raj Kumar Chauhan, Hon’Ble & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Suresh Kumar Gupta, CAFor Respondent: Shri Ankush Kalra, Sr. DR
Section 119Section 139(1)Section 143Section 154Section 234BSection 250Section 90

Nitin Khurana Addition Amount (Rs.) Tax liability in Return 0 Addition on account 47,309 of disallowance of foreign tax credit claimed u/s 90 of DTAA due to delay in filing of Form 67 Addition on account 8,351 of Interest on above Net Tax Liability 55,660 2. That ... JCIT (A) -2, Office of the Commissioner of Income Tax Appeal has erred both on facts and law in confirming disallowance of the Foreign Tax credit claimed under section 90/90A to the extent of Rs. 47,309/- by passing the Order u/s 250 of the Income Tax Act, 1961 dated

ERICSSON INDIA GLOBAL SERVICES PVT LTD,NEW DELHI vs. ACIT SPL. RANGE 3, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 2367/DEL/2019[2013-14]Status: DisposedITAT Delhi12 Mar 2026AY 2013-14

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singhassessment Year : 2013-14

For Appellant: Shri Paras S. Savla, AdvocateFor Respondent: Shri M.S. Nethrapal, CIT-DR
Section 143(1)Section 143(13)Section 143(2)Section 143(3)Section 144C(3)Section 234BSection 234CSection 254(2)Section 92C

assessee had filed its original return of income for 3 assessment year 2013-14 declaring total income of Rs.302,63,71,210/- claiming Foreign Tax Credit (FTC) of Rs.1,60,87,785/-. Thereafter, the assessee filed revised return of income on 31st March, 2015 to enhance FTC claim to Rs.3

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. RELIANCE RETAIL LIMITED, MUMBAI

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

ITA 4244/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

donation amounting to Rs. 21,06,00,000 given to entities registered u/s 80G to meet Corporate Social Responsibility. Additional claim of foreign tax credit not granted: Rs. 78,67,620 5. Erred in disallowing the additional claim of foreign tax credit of Rs. 78,67,620 on the ground ... date of filing the Return of Income (‘ROI’); 6. Erred in not entertaining the additional claim made by the Appellant of foreign tax credit, merely due to procedural delay in filing Form 67 by the Appellant and disregarding the fact that the Appellant had duly complied with the conditions prescribed

RELIANCE RETAIL LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 8(1)(1), MUMBAI

In the result, the appeal filed by the Revenue is dismissed,\nwhereas the appeal filed by the assessee is partly allowed

ITA 3510/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20
Section 135Section 143(3)Section 144BSection 14ASection 250Section 80GSection 80JSection 92C

AJIO marketing expenditure and addition on\naccount of creditors written back. The disallowance under section\n80G and certain other issues relating to foreign tax credit were\ndecided against the assessee.\n6.\nAggrieved by the order of the CIT(A), the Revenue is in\nappeal before the Tribunal and has raised ... donation amounting to Rs.\n21,06,00,000 given to entities registered u/s 80G to meet\nCorporate Social Responsibility.\nAdditional claim of foreign tax credit not granted: Rs. 78,67,620\n5. Erred in disallowing the additional claim of foreign tax credit of\nRs. 78,67,620 on the ground

AMITH VISHNAV GUDIMELLA,HYDERABAD vs. ITO, WARD-12(1), HYDERABAD, HYDERABAD

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 1705/HYD/2025[2020-21]Status: HeardITAT Hyderabad06 Mar 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1705/Hyd/2025 Assessment Year 2020-2021 Amith Vishnav The Income Tax Officer, Gudimella, Hyderabad. Ward-12(1), Pin – 500 008. Telangana. Vs. Hyderabad. Pan Aghpv2565J Telangana. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By Sri T Chaitanya Kumar, Advocate राज" व "ारा/Revenue By : Ms Reema Yadav, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 03.03.2026 घोषणा की तारीख/Pronouncement: 06.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: MS Reema Yadav, Sr. AR
Section 143(1)Section 154Section 90Section 91

Commissioner of Income Tax (Appeals) erred in upholding the order of the CPC Bangalore u/s 143(1) in making adjustments and disallowing the Foreign Tax Credit (FTC) while processing the return under Section 143(1). The said adjustment involves a debatable issue which cannot be rectified or adjusted under ... Hence, the addition made is invalid and liable to be deleted. 5. The learned CIT(A) erred in upholding the disallowance of the Foreign Tax Credit merely on technical grounds relating to the filing of Form-67 after the due date, without appreciating that the appellant had duly paid foreign

SHRI. JOHN KISHORE,TAMIL NADU vs. ASSESSING OFFICER, MADURAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 4090/CHNY/2025[2020-21]Status: DisposedITAT Chennai02 Mar 2026AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 4090/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Shri John Kishore, The Deputy Commissioner No.13, Munsif Court South Vs. Of Income Tax, Street, Sattur, Non-Corporate Circle 2, Virudhunagar – 626 203. Madurai Pan: Aztpj 1241L (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S.P. Chidambaram, Advocate ""यथ" क" ओर से/Respondent By : Shri Aroon Praasad, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 02.03.2026 आदेश/ O R D E R Per George George K: This Appeal Filed By The Assessee Is Directed Against The Addl./Jcit(A)’S, Indore Order Dated 09.10.2025 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Year Is 2020-21. :- 2 -: 2. The Solitary Issue That Is Raised Is Whether The First Appellate Authority (Faa) Had Erred In Law & On Facts In Not Granting Foreign Tax Credit (Ftc) Of Rs.5,73,078/-.

For Appellant: Shri S.P. Chidambaram, AdvocateFor Respondent: Shri Aroon Praasad, Addl.CIT
Section 119(2)(b)Section 139(1)Section 139(5)Section 143(1)Section 154Section 250Section 90

solitary issue that is raised is whether the First Appellate Authority (FAA) had erred in law and on facts in not granting Foreign Tax Credit (FTC) of Rs.5,73,078/-. 3. Brief facts of the case are as follows: The assessee was employed with Continental Automobile Components India ... reading of Rule 128 of the Rules, we find that sub-rule (9) of Rule 128 does not provide for disallowance of foreign tax credit in case of delay in filing Form No. 67. It is noted that filing of Form No. 67 is not mandatory but a directory requirement

XERAGO E-BIZ SERVICES PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD-3(3), CHENNAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 4067/CHNY/2025[2021-22]Status: DisposedITAT Chennai27 Feb 2026AY 2021-22

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 4067/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 Xerago E-Biz Services Pvt. The Income Tax Officer, Ltd., Vs. Corporate Ward 3(3), Plot No.80 & 93, Developed Plot, Chennai Xerago Towers, Industrial Estate, Perungudi, Chennai – 600 096 Pan: Aaacx 0387J (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri H. Yeshwanth Kumar, Advocate ""यथ" क" ओर से/Respondent By : Shri Aroon Praasad, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 25.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 27.02.2026 आदेश/ O R D E R Per George George K, Vp: This Appeal Filed By The Assessee Is Directed Against The Addl./Jcit(A), Varanasi Order Dated 31.10.2025 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Year Is 2021-22. :- 2 -: 2. The Grounds Raised Read As Follows:- 1. For That The Order Of The Additional / Joint Commissioner Of Income Tax (Appeals) Is Contrary To Law, Facts & Circumstances Of The Case & At Any Rate Is Opposed To The Principles Of Equity, Natural Justice & Fair Play.

For Appellant: Shri H. Yeshwanth KumarFor Respondent: Shri Aroon Praasad, Addl.CIT
Section 143(1)Section 154Section 250Section 90

derived no benefit by filing the appeal belatedly and that the same could not have been the intention of the appellant. Denial of Foreign Tax Credit to the tune of Rs. 26,17,160/-u/s.90 6. For that the denial of foreign tax relief to the tune of Rs.26 ... appellant had satisfied all the conditions specified u/s 90 of the Act for claiming the foreign tax relief. :- 3 -: 10. For that the foreign tax credit as claimed by the appellant was not allowed in the computation while the same was considered as allowance in Annexure TR (As computed

GOPAL KRISHNAN GOPINATH,CHENNAI vs. ASSESSING OFFICER INTERNATIONAL TAXATION, BSNL BUILDING GREAMS ROAD CHENNAI

In the result, the appeal filed by the assessee is dismissed

ITA 3878/CHNY/2025[2020-2021]Status: DisposedITAT Chennai20 Feb 2026AY 2020-2021

Bench: Shri Inturi Rama Rao & Shri Manu Kumar Giri

For Appellant: Mr. Balamurugan MFor Respondent: Ms. R. Anitha, Addl. CIT
Section 139(1)Section 143(1)Section 89

tax laws. The appellant duly declared this foreign income in the return of income filed for AY 2020-21 and claimed appropriate Foreign Tax Credit. The Form 16 issued by Infosys clearly shows the Foreign Tax Credit in the annexure, though erroneously categorized under "Relief under Section ... paid were legitimate and properly documented. 3. The main issue of the assessee is whether in the facts of the case credit for Foreign Tax Credit [for short FTC] as per Form 67 filed by the assessee is allowable? 4. We find that this is covered against the assesee

SHIPIJ RATHORE,INDORE vs. INCOME TAX OFFICER 1(2), INDORE

Appeal is allowed for statistical purpose

ITA 557/IND/2025[2021-2022]Status: DisposedITAT Indore19 Feb 2026AY 2021-2022
Section 143(1)Section 154Section 90

para 4.1 to 4.3\nof the impugned order as under:\n“4.1 The Appellant is aggrieved by the denial of foreign tax credit of\nRs.20,18,309/-, which according to CPC is not available when form\n67 has not been filed before the time limit specified u/s.139(1). A\nnotice ... payers like that of the Appellant, it is\nbrought on record that filing of Form no.67 is mandatory to claim the\nbenefit of Foreign Tax Credit.\n4.3 Taxes are paid in an alien nation, the particulars of which can\nnever be verified by the Income tax Authorities

VIMARSH PRAKASHBHAI VASAVADA,VADODARA, GUJARAT vs. INCOME TAX OFFICER WARD 1(2)(2), VADODARA, VADODARA, GUJARAT

The appeal of the assessee is allowed for statistical purposes subject to payment of cost

ITA 2653/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad17 Feb 2026AY 2020-21

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rignesh Das, CIT-DRFor Respondent: Shri Rignesh Das, CIT-DR
Section 115BSection 143(3)Section 144BSection 234BSection 234CSection 271ASection 54FSection 69A

denying the deduction. Accordingly, the CIT(Appeals) also dismissed this Ground of Appeal. 7. As regards the ground relating to allowance of foreign tax credit of ₹3,28,99,152/-, the CIT(Appeals) noted that no details or supporting documents were filed during the appellate proceedings to establish eligibility ... unexplained money under section 69A of the Act and by denying the consequential claims of deduction under section 54F of the Act and foreign tax credit. It is also equally evident that during the appellate proceedings before the CIT(Appeals), the assessee did not comply with the notices issued

TABASSUM ABDULLA INAMDAR,MUMBAI vs. DCIT 42(3)(1), MUMBAI

In the result, appeal of the assessee is allowed

ITA 6561/MUM/2025[2018-19]Status: DisposedITAT Mumbai16 Feb 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Girish Agrawalassessment Year: 2018-19

For Appellant: Shri Sunil Hirawat, CAFor Respondent: Shri Hemanshu Joshi, Sr. DR
Section 139(1)Section 143(1)Section 154Section 90

under: 1. On facts and in law, the Ld. Commissioner of Income Tax (Appeals) had erred in not allowing the credit of foreign tax credit claimed of Rs. 90,208/-Under the facts and circumstances of the matter, the claim of the appellant ought to have been allowed. 2 Tabassum ... issuing intimation dated 14.06.2020, raising a demand of Rs. 1,18,190/- which arose on account of denial of foreign tax credit claimed by the assessee amounting to Rs. 90,208/-. 3.2. Assessee had moved an application of rectification u/s. 154 of the Act dated 03.03.2025 along with filing

DCIT (INTERNATIONAL TAXATION)-2, HYDERABAD vs. THOGARCHEDU SUBHA SRI, HYDERABAD

In the result, the appeal of the Revenue is dismissed

ITA 1058/HYD/2025[2023-24]Status: DisposedITAT Hyderabad11 Feb 2026AY 2023-24
For Appellant: Shri BG Reddy, AdvocateFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 115A(1)(a)Section 143(1)Section 154Section 90(4)Section 90(5)

decision of the Visakhapatnam Bench of the\nTribunal in the case of Muralikrishna Vaddi Vs. ACIT/DCIT (ITA No.269/Viz/2021\ndated 14.06.2022), wherein foreign tax credit was denied due to delayed filing\nof Form No.67 beyond the due date under section 139(1) of the Act. It was\nfurther contended that rectification

HEMLATA PATEL,DEWAS vs. INCOME TAX OFFICER , DEWAS

In the result, the Appeal of the assessee is allowed for\nstatistical purpose

ITA 410/IND/2025[2023-2024]Status: DisposedITAT Indore06 Feb 2026AY 2023-2024
Section 139(1)Section 139(4)Section 143(1)Section 250Section 253Section 90

income of Rs.35,30,130/-. Further the assessee filed\nthe form no.67 on 31st December 2023 vide\nacknowledgment no.603117750311223 for the availment\nof foreign tax credit of Rs.1,49,437/- being TDS in UK on\nthe pension income. The return was processed u/s 143(1) of\nthe Act in which ... filed within the prescribed time limit.\n6.3 The appellant through grounds of appeal submitted with Form\n35 contended that CPC erred in disallowing foreign tax credit of\nRs. 1,49,437, without assigning any reason for the same.\n6.4 In this context, it is noted that a taxpayer residing

TATA CHEMICALS LTD.,MUMBAI vs. DY CIT 2 (3)(1), MUMBAI

ITA 7912/MUM/2019[2015-16]Status: DisposedITAT Mumbai04 Feb 2026AY 2015-16
For Appellant: \nMr. Nitesh Joshi a/wFor Respondent: \nMr. Ajay Chandra, CIT-DR
Section 14ASection 35Section 43BSection 80Section 91Section 92Section 92A(3)

Income Tax erred in not\nallowing the claim of provision for bad and doubtful debts,\namounting to Rs. 9,70,98,738/-\n9. Foreign tax Credit : Rs. 15,71,220/-\nThe learned Deputy Commissioner of Income Tax erred in not\ngranting Credit for Taxes withheld in foreign country

ROHAN ATUL KHADILKAR ,PUNE vs. ITO, WARD 13(1), PUNE , PUNE

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1200/PUN/2024[2021-22]Status: DisposedITAT Pune02 Feb 2026AY 2021-22

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.1200/Pun/2024 Assessment Year : 2021-22

For Appellant: Shri Kishor PhadkeFor Respondent: Date of hearing
Section 139(1)Section 143(1)Section 143(1)(a)Section 250Section 90

dated 26.09.2025 in M.A.No.56/PUN/2025. 3. Assessee has raised following grounds of appeal : “1. The appellant contends that, the appellant is entitled to foreign tax credit of Rs. 84,375/- pertaining to the foreign sourced salary income of Rs. 10,90,200 which is doubly taxed ... well as India considering the fact that the appellant has filed Form 67 so as to enable him to claim such Foreign Tax Credit. 2 Rohan Atul Khadilkar 2. The lower IT authorities ought to have appreciated that. • Rule 128(9) of the IT Rules does not provide for disallowance

PRAPHAPANANEE SEKARBABU VIGNESH,CHENNAI vs. ITO, NCW-10(3), CHENNAI

In the result, the appeal of the assessee stands allowed

ITA 2496/CHNY/2025[2022-23]Status: DisposedITAT Chennai02 Feb 2026AY 2022-23

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. Suraj Nahar, C.AFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T
Section 139(1)Section 154Section 90

short] dated 12.08.2025 in the matter of intimation order u/s.154 r.w.s 143(1) of the Act passed on 15.06.2023 denying Foreign Tax Credit of Rs.4,93,235/- as claimed by the assessee u/s 90/90A of the Act. The same was denied for delay in filing of requisite Form 67 along ... Form 67 was filed by the assessee on 30.09.2022 after the due date. The AO denied the claim of Foreign Tax Credit for the reason that the assessee has failed to submit the Form 67 within the due date prescribed u/s.139(1) of the Act. However, Ld. AR relied

ASHOK SETHI,DELHI vs. ACIT CIRCLE- 70(1), NEW DELHI

In the result, the appeal filed by the assessee is allowed

ITA 5526/DEL/2025[2018-19]Status: DisposedITAT Delhi02 Feb 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2018-19 Sh. Ashok Sethi, Vs. Acit, 18, Sunder Nagar, Circle-70(1), Delhi New Delhi Pan: Bqqps1160L (Appellant) (Respondent) Assessee By Sh. Shailendra Mohan, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 02.02.2026 Date Of Pronouncement 02.02.2026 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Commissioner Of Income Tax (Appeals)/Addl. Jcit(A)- 2, Chennai’S Din & Order No. Itba/Apl/S/250/2025- 26/1078504613(1), Dated 15.07.2025, Involving Proceedings Under Section 154 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case File Perused. 2. Suffice To Say, It Transpires During The Course Of Hearing That Both The Learned Lower Authorities Have Denied The Assessee’S Foreign Tax Credit Claim Of Rs.1,28,946/- Under Section 90 R.W.S. 90A Of The Act For The Sole Reason That He Had Not Filed/Uploaded His Corresponding Form 67 On Or Before The Prescribed “Due” Date In The Course Of Section 154 “Rectification”, Dated 18Th August, 2022 & Upheld In The Lower Appellate Discussion. This Is What Leaves The Assessee Aggrieved. 4. We Have Given Our Thoughtful Consideration To The Assessee’S & Department’S Vehement Arguments Reiterating Their Respective Stands. It Further Emerges That The Assessee Had Subsequently Complied With The Above Form 67 Filing/Uploading Post Facto The Due Date Thereof As Admitted By Both The Parties. & Also, That Instant Identical Issue Has Been Decided By This Tribunal In Gurcharan Singh Vs. Ito

Section 139Section 139(1)Section 154Section 90

perused. 2. Suffice to say, it transpires during the course of hearing that both the learned lower authorities have denied the assessee’s foreign tax credit claim of Rs.1,28,946/- under section 90 r.w.s. 90A of the Act for the sole reason that he had not filed/uploaded his corresponding ... Rules for our perusal. The relevant extract is cited for ease of reference: 2 | P a g e “Foreign Tax Credit. 128. (1) An assessee, being a resident shall be allowed a credit for the amount of any foreign tax paid by him in a country or specified territory outside

RAVIKIRAN GOPALRAO ALAVANDI,PUNE vs. INCOME-TAX OFFICER, PUNE

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2939/PUN/2025[2021-22]Status: DisposedITAT Pune30 Jan 2026AY 2021-22

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2939/Pun/2025 Assessment Year : 2021-22

For Respondent: Assessee by Shri Anup Shaha
Section 139(1)Section 143(1)Section 143(1)(a)Section 250Section 90

ordinary resident of India. During the period relevant to the assessment year under consideration the assessee worked in Germany and claimed Foreign Tax Credit (FTC) of Rs.6,35,346/- in the original return of income filed on 29.10.2021 u/s.90/91 of the Act read with Article 23 of the Double Taxation ... rival submissions and perused the record placed before me. The short issue for my consideration is whether the assessee is entitled to Foreign Tax Credit. During the year under consideration, the assessee worked the assessee worked in Germany and claimed Foreign Tax Credit of Rs.6,35,346/- for the services

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

ITA 294/BANG/2025[2021-22]Status: DisposedITAT Bangalore30 Jan 2026AY 2021-22
For Appellant: \nShri Padamchand Kincha, CAFor Respondent: \nShri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

such foreign taxes were paid by way of tax deduction\nat source by the foreign payers.\n38.1 For the purpose of claiming Foreign Tax Credit (FTC) in India, the\nassessee computed the eligible credit on the basis of net income in\naccordance with the provisions of section ... receipts. Consequently, a portion of the foreign\ntax paid, which was not eligible for relief under section 90, could not be\nclaimed as foreign tax credit in the return of income.\n38.2 The assessee, therefore, did not claim such excess foreign tax\npaid as FTC. The amount of foreign tax

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 293/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

such foreign taxes were paid by way of tax deduction at source by the foreign payers. 38.1 For the purpose of claiming Foreign Tax Credit (FTC) in India, the assessee computed the eligible credit on the basis of net income in accordance with the provisions of section ... receipts. Consequently, a portion of the foreign tax paid, which was not eligible for relief under section 90, could not be claimed as foreign tax credit in the return of income. 38.2 The assessee, therefore, did not claim such excess foreign tax paid as FTC. The amount of foreign tax

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