Tax Credit Allowed for Indo-Japan Treaty: Incorrect Denial Overturned Due to Distinct Provisions and Judicial Precedents Misapplied.

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....Allowance of credit of taxes as withheld by the clients domiciled in Japan - The judicial precedents cited by the authorities below are in the context of the tax treaties other than Indo Japan tax treaty, and the provisions of the Indo Japan tax treaty are not in pari materia with the provisions of those tax treaties. - the assessee was wrongly declined tax credit on the facts of this case. - AT....