Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The amount of tax paid in a foreign country which is not eligible for benefit u/s 91 of the Act, is expenditure eligible for deduction u/s 37(1) of the Act. It is because such tax was paid in the course of the business and the corresponding business receipts were made to tax in India. We hold that the assessee is eligible for deduction for the amount of foreign tax credit which was not allowed as tax relief u/s 91 of the Act.
The amount of tax paid in a foreign country which is not eligible for benefit u/s 91 of the Act, is expenditure eligible for deduction u/s 37(1) of the Act. It is because such tax was paid in the course of the business and the corresponding business receipts were made to tax in India. We hold that the assessee is eligible for deduction for the amount of foreign tax credit which was not allowed as tax relief u/s 91 of the Act.
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