Foreign exchange repatriation enables retrospective allowance of deductions for dividends and similar overseas receipts. Where income by way of dividends, royalty, commission, fees or similar payments was disallowed for deduction solely because it was not received in, or brought into, India in convertible foreign exchange, but is subsequently received in or brought into India in accordance with foreign exchange laws, the Income tax Officer shall amend the assessment to allow the deduction and apply the assessment revision provisions, with the four year amendment period reckoned from the date the income is so received or brought into India.
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Provisions expressly mentioned in the judgment/order text.
Foreign exchange repatriation enables retrospective allowance of deductions for dividends and similar overseas receipts.
Where income by way of dividends, royalty, commission, fees or similar payments was disallowed for deduction solely because it was not received in, or brought into, India in convertible foreign exchange, but is subsequently received in or brought into India in accordance with foreign exchange laws, the Income tax Officer shall amend the assessment to allow the deduction and apply the assessment revision provisions, with the four year amendment period reckoned from the date the income is so received or brought into India.
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