https://www.taxtmi.com/caselaws?id=796599 Foreign tax credit is available to a resident partnership firm for overseas taxes withheld from professional receipts included in its taxable income in India, where prescribed documentation, including Form 67 and authenticated withholding certificates, is furnished. Under the Indo-Japan treaty, the independent personal services provision did not apply to the partnership firm in the relevant context and did not exclude its services from fees for technical services treatment. Section 90 and Section 90A of the Income-tax Act, read with Rule 128, therefore did not support denial of credit where treaty-based withholding was not shown to be erroneous. en-us Fri, 31 Jul 2026 00:00:00 +0530 Fri, 07 Aug 2026 09:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796599 Foreign tax credit is available to a resident partnership firm for overseas taxes withheld from professional receipts included in its taxable income in India, where prescribed documentation, including Form 67 and authenticated withholding certificates, is furnished. Under the Indo-Japan treaty, the independent personal services provision did not apply to the partnership firm in the relevant context and did not exclude its services from fees for technical services treatment. Section 90 and Section 90A of the Income-tax Act, read with Rule 128, therefore did not support denial of credit where treaty-based withholding was not shown to be erroneous. Case-Laws Income Tax Fri, 31 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796599