Section 10A relief and foreign tax credit issues were resolved for the assessee on binding precedent.

Rental income linked to the assessee's business operations was treated as eligible for Section 10A relief, and the document states that this issue was answered in the assessee's favour. Foreign tax credit for income exempt under Section 10A, including credit for state taxes paid outside India, was also stated to be allowable on the basis of binding precedent. Recomputing the Section 10A deduction by the Assessing Authority was likewise stated to be unsustainable. The Revenue's appeal was therefore not accepted, and the assessee succeeded on all questions of law.

---

---

Issues: (i) Whether rental income from Infosys BPO Ltd. and BSNL Chennai Ltd. was eligible for treatment as profits derived under Section 10A of the Income-tax Act, 1961; (ii) Whether foreign tax credit under Section 90 of the Income-tax Act, 1961 was allowable in respect of income exempt under Section 10A; (iii) Whether credit for state taxes paid outside India was allowable; (iv) Whether recomputation of Section 10A by the Assessing Authority was liable to be set aside.

Issue (i): Whether rental income from Infosys BPO Ltd. and BSNL Chennai Ltd. was eligible for treatment as profits derived under Section 10A of the Income-tax Act, 1961.

Analysis: The question was treated as covered by the decision rendered in the connected appeal decided on the same day.

Conclusion: The issue was answered in favour of the assessee.

Issue (ii): Whether foreign tax credit under Section 90 of the Income-tax Act, 1961 was allowable in respect of income exempt under Section 10A.

Analysis: The question was treated as covered by the decision in Wipro Ltd. v. Deputy Commissioner of Income-tax.

Conclusion: The issue was answered in favour of the assessee.

Issue (iii): Whether credit for state taxes paid outside India was allowable.

Analysis: The question was treated as covered by the decision in Wipro Ltd. v. Deputy Commissioner of Income-tax.

Conclusion: The issue was answered in favour of the assessee.

Issue (iv): Whether recomputation of Section 10A by the Assessing Authority was liable to be set aside.

Analysis: The question was treated as covered by the decision in Commissioner of Income-tax v. HCL Technologies Ltd.

Conclusion: The issue was answered in favour of the assessee.

Final Conclusion: The Revenue's appeal was not accepted and the assessee succeeded on all questions of law.

Ratio Decidendi: Where the issues raised are covered by binding precedent, the court will answer the questions consistently with those precedents and dismiss the revenue appeal.

---