Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
Foreign tax credit rules limit relief to resident assessees, requiring prescribed filing, proof, and apportionment across years. Resident assessees are allowed foreign tax credit for tax paid outside India in the year the corresponding income is taxed in India, with apportionment where the income is taxed over more than one year. The credit is limited to tax, surcharge and cess, excludes disputed foreign tax until settlement, and is computed separately for each foreign source at the lower of Indian tax on the income and foreign tax paid. Credit depends on filing Form No. 67 and supporting evidence within the prescribed time.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Foreign tax credit rules limit relief to resident assessees, requiring prescribed filing, proof, and apportionment across years.
Resident assessees are allowed foreign tax credit for tax paid outside India in the year the corresponding income is taxed in India, with apportionment where the income is taxed over more than one year. The credit is limited to tax, surcharge and cess, excludes disputed foreign tax until settlement, and is computed separately for each foreign source at the lower of Indian tax on the income and foreign tax paid. Credit depends on filing Form No. 67 and supporting evidence within the prescribed time.
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