The Bangalore Bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of ITTIAM Systems Pvt Ltd (the taxpayer) dealt with the issue of eligibility of Foreign Tax Credit (FTC) on the taxes paid in various foreign countries. The Tribunal held that the taxpayer is eligible for full credit of FTC, amounting to taxes paid in USA, Japan and Germany under respective tax treaties. However, in the case of Korea, FTC is limited to taxes paid in Korea or India, whichever is less.
With Taiwan, India does not have a tax treaty. Therefore, FTC is to be computed based on rate of tax applicable in India or Taiwan, whichever is less, on such doubly taxable income
Subscribe to:
Post Comments (Atom)
Recommendations of 55th GST council meeting | 21 December 2024
Summary of the relevant updates is provided below for ease of your reference: A) Proposals relating to GST law, Compliances an...
-
PCIT vs. The Executor of Estate of Late Smt. Manjula A. Shah (Bombay High Court) S. 50C Capital Gains: The valuation of the stamp autho...
-
This Tax Alert summarizes a recent ruling of the Supreme Court (SC) [1] on availability of CENVAT Credit on mobile towers and pre-fabrica...
-
IFRS and US GAAP - Similarities and Differences What is IFRS? And what is GAAP? The main difference between IFRS and US GAAP is that G...
-
Madras HC reverses ITAT's order, grants deduction u/s. 80P(2)(a)(i) to assessee (a society engaged in the business of banking and provi...
-
SC dismisses assessee-company’s SLP challenging Bombay HC order upholding re-assessment initiation (beyond 4 yrs period) based on a special...
-
SC dismisses Revenue’s SLP challenging Bombay HC order in case of assessee (belonging to Lodha group of companies engaged in real estate bu...
-
Claiming a foreign tax credit (FTC) in Australia allows companies to offset foreign taxes paid on income earned overseas against their Aust...
-
HC allows HDFC Bank’s writ petition, quashes AO’s order and subsequent reference to TPO alleging that certain related party transactions [p...
-
Delhi ITAT deletes Rs. 1558.57 cr. capital gains addition on Telenor India for AY 2014-15, holds that set off of non-refundable entry fee p...
-
This Tax Alert summarizes a recent ruling of the Bombay High Court (HC)1 on admissibility of input tax credit (ITC) w.r.t GST on advance p...
No comments:
Post a Comment