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    <title>2021 (12) TMI 1359 - ITAT DELHI</title>
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    <description>Distribution revenue characterisation, permanent establishment status and the applicable treaty provision were resolved consistently with earlier years, resulting in deletion of the related additions. Tax deducted at source credit for revenue offered to tax in India requires verification; credit must be granted if the claim is substantiated. Credit for tax deducted at source on revenue not chargeable to tax in India may be denied where the corresponding income was not offered to tax in the return, with credit claimable in the jurisdiction where that income is taxed. The overall result was partial relief on the tax treatment and withholding-tax credit claims.</description>
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      <description>Distribution revenue characterisation, permanent establishment status and the applicable treaty provision were resolved consistently with earlier years, resulting in deletion of the related additions. Tax deducted at source credit for revenue offered to tax in India requires verification; credit must be granted if the claim is substantiated. Credit for tax deducted at source on revenue not chargeable to tax in India may be denied where the corresponding income was not offered to tax in the return, with credit claimable in the jurisdiction where that income is taxed. The overall result was partial relief on the tax treatment and withholding-tax credit claims.</description>
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