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    <title>2024 (12) TMI 810 - ITAT AHMEDABAD</title>
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    <description>Foreign tax credit for tax paid in China was treated as claimable in the assessment year when the tax was deducted and paid, because the treaty did not prescribe a contrary timing rule and the domestic credit mechanism under section 199 permitted such allowance. The Tribunal also held that foreign tax credit could be set off against tax computed under the minimum alternate tax regime, as the Act did not exclude MAT liability from the credit scheme. A proviso inserted into section 115JAA(2A) by the Finance Act, 2017 was held prospective and could not restrict MAT credit for the year under appeal. The assessee therefore succeeded on timing, MAT credit, and prospective application of the amendment.</description>
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      <title>2024 (12) TMI 810 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=763230</link>
      <description>Foreign tax credit for tax paid in China was treated as claimable in the assessment year when the tax was deducted and paid, because the treaty did not prescribe a contrary timing rule and the domestic credit mechanism under section 199 permitted such allowance. The Tribunal also held that foreign tax credit could be set off against tax computed under the minimum alternate tax regime, as the Act did not exclude MAT liability from the credit scheme. A proviso inserted into section 115JAA(2A) by the Finance Act, 2017 was held prospective and could not restrict MAT credit for the year under appeal. The assessee therefore succeeded on timing, MAT credit, and prospective application of the amendment.</description>
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