https://www.taxtmi.com/caselaws?id=337640 Foreign tax credit under the relevant tax treaties was analysed on the basis of the income element embedded in foreign receipts, not gross receipts. Where the assessee furnished a reasonable item-wise computation and it was not shown to be defective, a mechanical turnover-based allocation was unwarranted; the doubly taxed income was accepted on that basis. The credit itself remained capped at the Indian tax attributable to the relevant foreign income, and where Indian tax was paid under MAT, attributable tax was worked out by apportioning MAT in the ratio of double-taxed profit to overall profit for the Singapore and Indonesia receipts. On that computation, the admissible credit was enhanced to the amount determined by the Tribunal. en-us Tue, 03 Jan 2017 00:00:00 +0530 Tue, 10 Jan 2017 20:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=337640 Foreign tax credit under the relevant tax treaties was analysed on the basis of the income element embedded in foreign receipts, not gross receipts. Where the assessee furnished a reasonable item-wise computation and it was not shown to be defective, a mechanical turnover-based allocation was unwarranted; the doubly taxed income was accepted on that basis. The credit itself remained capped at the Indian tax attributable to the relevant foreign income, and where Indian tax was paid under MAT, attributable tax was worked out by apportioning MAT in the ratio of double-taxed profit to overall profit for the Singapore and Indonesia receipts. On that computation, the admissible credit was enhanced to the amount determined by the Tribunal. Case-Laws Income Tax Tue, 03 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=337640