Denial of FTC as income not offered to tax in the considered year not justifiable

DCIT Vs Suzlon Energy Ltd. (ITAT Ahmedabad) ITAT Ahmedabad held that denial of Foreign Tax Credit [FTC] on the ground that corresponding income has not been offered for tax in the year under appeal is not justifiable. Accordingly, FTC allowed. Facts- The assessee is a company engaged in the business of manufacturing Wind Turbine Generators [WTG], Rotor blades, etc. The assessee company rendered certain technical services to its Subsidiary company namely M/s. Suzlon Energy [Tianjin] Ltd at China [hereinafter referred as SETL] and earned royalty income aggregating to Rs.16,22,63,445/= and Rs.11,...