https://www.taxtmi.com/highlights?id=95809 Disallowance under s.14A r/w Rule 8D was held inapplicable where dividend-yielding shares were held as stock-in-trade; no proximate expenditure was established, so the disallowance was deleted. Exclusion of foreign branch profits was rejected; instead, treaty-based foreign tax credit (FTC) was to be granted upon verification of foreign taxes paid, non-claim earlier, and DTAA admissibility, and computed jurisdiction-wise; the issue was restored to the AO for limited verification. Carried-forward FTC for prior-year foreign taxes was allowed where the corresponding foreign income became taxable in India only when losses were set off; AO to cap credit to domestic tax incidence and verify, with remand. MAT under s.115JB was held inapplicable to ..... en-us Wed, 07 Jan 2026 08:39:36 +0530 Wed, 07 Jan 2026 08:39:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=95809 Disallowance under s.14A r/w Rule 8D was held inapplicable where dividend-yielding shares were held as stock-in-trade; no proximate expenditure was established, so the disallowance was deleted. Exclusion of foreign branch profits was rejected; instead, treaty-based foreign tax credit (FTC) was to be granted upon verification of foreign taxes paid, non-claim earlier, and DTAA admissibility, and computed jurisdiction-wise; the issue was restored to the AO for limited verification. Carried-forward FTC for prior-year foreign taxes was allowed where the corresponding foreign income became taxable in India only when losses were set off; AO to cap credit to domestic tax incidence and verify, with remand. MAT under s.115JB was held inapplicable to ..... Highlights Income Tax Wed, 07 Jan 2026 08:39:36 +0530 https://www.taxtmi.com/highlights?id=95809