https://www.taxtmi.com/caselaws?id=781274 Foreign tax credit under section 90 read with the India-Japan DTAA may be available even when the corresponding income suffers no Indian tax because of section 10A exemption or brought-forward losses; the credit mechanism is aimed at relieving double taxation and is not denied merely because no tax remains payable in India. Interest under section 244A, however, is confined to refunds of tax actually paid in India, such as advance tax or TDS, so foreign tax withheld abroad does not by itself create an interest-bearing refund. The substantive credit claim is thus distinct from the separate claim for statutory interest on refund. en-us Mon, 10 Nov 2025 00:00:00 +0530 Thu, 13 Nov 2025 08:14:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781274 Foreign tax credit under section 90 read with the India-Japan DTAA may be available even when the corresponding income suffers no Indian tax because of section 10A exemption or brought-forward losses; the credit mechanism is aimed at relieving double taxation and is not denied merely because no tax remains payable in India. Interest under section 244A, however, is confined to refunds of tax actually paid in India, such as advance tax or TDS, so foreign tax withheld abroad does not by itself create an interest-bearing refund. The substantive credit claim is thus distinct from the separate claim for statutory interest on refund. Case-Laws Income Tax Mon, 10 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781274