https://www.taxtmi.com/caselaws?id=400423 Section 90(2) of the Income-tax Act, 1961 and Article 24 of the India-UK DTAA were applied to allow foreign tax credit where the assessee, an Indian resident, had worked in the United Kingdom for more than 183 days and tax had in fact been paid there on the remuneration. Article 16(2) was found inapplicable on the stated facts, so it could not be used to deny relief. The treaty being more favourable, the assessee was entitled to credit for the UK taxes on the doubly taxed income, and the disallowance made by the lower authorities was held unsustainable. en-us Thu, 05 Nov 2020 00:00:00 +0530 Thu, 05 Nov 2020 17:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400423 Section 90(2) of the Income-tax Act, 1961 and Article 24 of the India-UK DTAA were applied to allow foreign tax credit where the assessee, an Indian resident, had worked in the United Kingdom for more than 183 days and tax had in fact been paid there on the remuneration. Article 16(2) was found inapplicable on the stated facts, so it could not be used to deny relief. The treaty being more favourable, the assessee was entitled to credit for the UK taxes on the doubly taxed income, and the disallowance made by the lower authorities was held unsustainable. Case-Laws Income Tax Thu, 05 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400423