https://www.taxtmi.com/caselaws?id=294344 Foreign tax credit for taxes paid in the United States, Japan and Germany was to be allowed in full under the relevant treaty provisions, because the ceiling was based on Indian tax attributable to the foreign-source income and not on a blanket apportionment by gross receipts. For Korea, the treaty applied a different limitation, so the credit had to be restricted to the Indian tax attributable to the Korean-source income. For Taiwan, where no treaty applied, relief fell under section 91 and had to be computed on the statutory comparison of Indian tax rate and foreign tax rate, whichever was lower. The alternative claim for deduction of foreign taxes was not adjudicated. en-us Wed, 13 Jan 2021 00:00:00 +0530 Tue, 27 Apr 2021 10:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=294344 Foreign tax credit for taxes paid in the United States, Japan and Germany was to be allowed in full under the relevant treaty provisions, because the ceiling was based on Indian tax attributable to the foreign-source income and not on a blanket apportionment by gross receipts. For Korea, the treaty applied a different limitation, so the credit had to be restricted to the Indian tax attributable to the Korean-source income. For Taiwan, where no treaty applied, relief fell under section 91 and had to be computed on the statutory comparison of Indian tax rate and foreign tax rate, whichever was lower. The alternative claim for deduction of foreign taxes was not adjudicated. Case-Laws Income Tax Wed, 13 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=294344