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Partnership firm rendered professional services in Japan, taxes withheld there. Firm claimed foreign tax credit (FTC) which was denied by tax authorities. ITAT held that under India-Japan tax treaty, firm's income taxable as fees for technical services, entitling it to FTC for Japanese taxes withheld. Even if interpretations differ between residence and source countries on treaty provisions, FTC cannot be denied when source country levies tax. ITAT allowed FTC for taxes withheld in Japan and other countries like Nepal, Brazil, China and Malaysia based on earlier ruling favoring the firm. Assessee's appeal allowed granting FTC.
Partnership firm rendered professional services in Japan, taxes withheld there. Firm claimed foreign tax credit (FTC) which was denied by tax authorities. ITAT held that under India-Japan tax treaty, firm's income taxable as fees for technical services, entitling it to FTC for Japanese taxes withheld. Even if interpretations differ between residence and source countries on treaty provisions, FTC cannot be denied when source country levies tax. ITAT allowed FTC for taxes withheld in Japan and other countries like Nepal, Brazil, China and Malaysia based on earlier ruling favoring the firm. Assessee's appeal allowed granting FTC.
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