https://www.taxtmi.com/caselaws?id=796414 Foreign tax credit was available for overseas tax withheld on professional legal-service receipts where the gross foreign income was included in taxable income in India. The notes state that the India-Japan DTAA characterised the receipts under Article 12(4), not Article 14, because Article 14 applied to individuals in that treaty framework; the foreign withholding was therefore not improperly imposed. Form 67 and authenticated foreign tax-deduction certificates were furnished, and there was no factual dispute over the receipts or tax withheld. Rule 128 imposed no restriction supporting denial of the 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 was available for overseas tax withheld on professional legal-service receipts where the gross foreign income was included in taxable income in India. The notes state that the India-Japan DTAA characterised the receipts under Article 12(4), not Article 14, because Article 14 applied to individuals in that treaty framework; the foreign withholding was therefore not improperly imposed. Form 67 and authenticated foreign tax-deduction certificates were furnished, and there was no factual dispute over the receipts or tax withheld. Rule 128 imposed no restriction supporting denial of the credit. Case-Laws Income Tax Fri, 31 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796414