Entire Foreign Tax Credit allowed inspite of NIL taxability on account of 10A exemption

Canon India Pvt Ltd Vs DCIT (ITAT Delhi)

ITAT Delhi held that the assessee is eligible for entire credit of foreign taxes, even if the taxability was nil consequent to the deduction on account of business losses or section 10A exemption. Accordingly, appeal is allowed.

Facts- During the Assessment Year 2003-04, the assessee earned certain income from its operations in Japan, on which taxes amounting to RS 20,39,37,900/- were withheld in Japan in accordance with the domestic tax laws of that jurisdiction. In its return of income filed in India, the assessee

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