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2021 (10) TMI 1011 - AT - Income TaxCredit of tax paid in Japan - claim of foreign tax credit - Disallowing complete credit of taxes paid by appellant in Japan on income from sale of software under Article 23 of India-Japan Double Taxation Avoidance Agreement - HELD THAT:- We find that the India-Japan DTAA is worded in similar lines with that of India-USA DTAA. Therefore, the aforesaid decision quoted by this Tribunal in HCL COMNET SYSTEMS AND SERVICES LTD VERSUS THE DY. C.I.T CIRCLE – 12 (1) NEW DELHI [2020 (7) TMI 169 - ITAT DELHI] squarely applies on the facts of the case in hand. Therefore, we direct accordingly. Application of incorrect rate of MAT - We direct the Assessing Officer to consider the applicable rate of MAT for the year under consideration as per provisions of law.
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