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        Case ID :
        Income Tax

        Foreign Tax Credit (‘FTC’) - Cases in which no FTC benefit would be available

        30 June, 2016

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        Rule - 128 - Foreign Tax Credit

        No FTC benefit against interest, fee or penalty payable under the Act.

        No FTC benefit of foreign tax or part thereof which is disputed in any manner by the assessee.

        Foreign Tax Credit denial: no credit for domestic interest, fees or penalties and for disputed foreign taxes. Rule 128 restricts Foreign Tax Credit by disallowing FTC against interest, fees or penalties payable under the Income-tax Act, and by excluding any foreign tax (or part thereof) that is disputed by the assessee.
                    Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                      Provisions expressly mentioned in the judgment/order text.

                          Foreign Tax Credit denial: no credit for domestic interest, fees or penalties and for disputed foreign taxes.

                          Rule 128 restricts Foreign Tax Credit by disallowing FTC against interest, fees or penalties payable under the Income-tax Act, and by excluding any foreign tax (or part thereof) that is disputed by the assessee.


                          Note: It is a system-generated summary and is for quick reference only.
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