https://www.taxtmi.com/caselaws?id=796414 Foreign tax credit is available for overseas tax withheld on professional legal-service receipts where the gross foreign income is included in taxable income in India. Professional receipts from Japanese clients are characterised under Article 12(4) of the India-Japan DTAA rather than the independent personal services provision, which applies to individuals. Credit may be claimed where the taxpayer has rendered the services abroad, filed Form 67, and furnished authenticated foreign tax-deduction certificates. Where the foreign receipts and corresponding withholding are undisputed, Rule 128 does not impose a restriction denying credit. en-us Fri, 31 Jul 2026 00:00:00 +0530 Wed, 05 Aug 2026 08:48:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796414 Foreign tax credit is available for overseas tax withheld on professional legal-service receipts where the gross foreign income is included in taxable income in India. Professional receipts from Japanese clients are characterised under Article 12(4) of the India-Japan DTAA rather than the independent personal services provision, which applies to individuals. Credit may be claimed where the taxpayer has rendered the services abroad, filed Form 67, and furnished authenticated foreign tax-deduction certificates. Where the foreign receipts and corresponding withholding are undisputed, Rule 128 does not impose a restriction denying credit. Case-Laws Income Tax Fri, 31 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796414