Foreign Tax Paid Not Qualifying u/s 91 is Deductible as Business Expense u/s 37(1.

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....The amount of tax paid in a foreign country which is not eligible for benefit u/s 91 of the Act, is expenditure eligible for deduction u/s 37(1) of the Act. It is because such tax was paid in the course of the business and the corresponding business receipts were made to tax in India. We hold that the assessee is eligible for deduction for the amount of foreign tax credit which was not allowed as tax relief u/s 91 of the Act.....