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    <title>2015 (6) TMI 164 - ITAT MUMBAI</title>
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    <description>Rectification applications under section 154 were treated as timely because the four-year period ran from the assessment order sought to be rectified, and the omission to deal with the claimed foreign tax credit could be examined as a mistake apparent from the record. On the substantive issue, income covered by section 10A remained part of chargeable total income after the provision was amended to operate as a deduction from total income, so foreign tax credit was not denied merely because the same income had domestic deduction relief. Applying the India-Japan treaty, the assessee was held entitled to credit for tax deducted in Japan against Indian tax on the corresponding income.</description>
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      <link>https://www.taxtmi.com/caselaws?id=260239</link>
      <description>Rectification applications under section 154 were treated as timely because the four-year period ran from the assessment order sought to be rectified, and the omission to deal with the claimed foreign tax credit could be examined as a mistake apparent from the record. On the substantive issue, income covered by section 10A remained part of chargeable total income after the provision was amended to operate as a deduction from total income, so foreign tax credit was not denied merely because the same income had domestic deduction relief. Applying the India-Japan treaty, the assessee was held entitled to credit for tax deducted in Japan against Indian tax on the corresponding income.</description>
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