https://www.taxtmi.com/caselaws?id=304159 ITAT Delhi held that a conclusive clarification from the Omani tax authority on dividend-related tax had to be accepted for treaty tax credit purposes under section 90, so the revenue could not substitute its own interpretation of the foreign tax position; the assessee was therefore entitled to the credit. It also held that no notional interest disallowance under section 36(1)(iii) could be sustained because the assessee's own interest-free funds exceeded the relevant investments and capital work-in-progress, making the revenue's mixed-funds objection unsustainable. Both issues were decided in favour of the assessee, and the appellate order was upheld. en-us Fri, 25 Mar 2022 00:00:00 +0530 Sat, 10 Sep 2022 07:01:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304159 ITAT Delhi held that a conclusive clarification from the Omani tax authority on dividend-related tax had to be accepted for treaty tax credit purposes under section 90, so the revenue could not substitute its own interpretation of the foreign tax position; the assessee was therefore entitled to the credit. It also held that no notional interest disallowance under section 36(1)(iii) could be sustained because the assessee's own interest-free funds exceeded the relevant investments and capital work-in-progress, making the revenue's mixed-funds objection unsustainable. Both issues were decided in favour of the assessee, and the appellate order was upheld. Case-Laws Income Tax Fri, 25 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304159