https://www.taxtmi.com/caselaws?id=762030 Foreign tax credit under section 90 was held allowable where professional service income was subjected to withholding tax in Japan, Nepal and Singapore under the relevant DTAA framework and the income was offered to tax in India. The ITAT Mumbai applied earlier coordinate-bench rulings on materially identical facts, including the India-Japan, India-Singapore and India-Nepal treaty provisions, and held that credit could not be denied merely because the Revenue viewed the source-country taxation as inconsistent with its own treaty interpretation. The Tribunal also relied on the principle of consistency, found no distinguishing facts, and rejected the Revenue's challenge. en-us Mon, 21 Oct 2024 00:00:00 +0530 Thu, 21 Nov 2024 10:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762030 Foreign tax credit under section 90 was held allowable where professional service income was subjected to withholding tax in Japan, Nepal and Singapore under the relevant DTAA framework and the income was offered to tax in India. The ITAT Mumbai applied earlier coordinate-bench rulings on materially identical facts, including the India-Japan, India-Singapore and India-Nepal treaty provisions, and held that credit could not be denied merely because the Revenue viewed the source-country taxation as inconsistent with its own treaty interpretation. The Tribunal also relied on the principle of consistency, found no distinguishing facts, and rejected the Revenue's challenge. Case-Laws Income Tax Mon, 21 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762030