Indo-Thai DTAA Article 23 – Tax Credit Applies Only When Tax Paid

PCIT Vs Polyplex Corporation Ltd (Delhi High Court)

Delhi High Court held that tax credit could not be extended to the assessee, because it had not paid tax in Thailand, i.e., that benefit under Article 23 of the Indo-Thai DTAA could only be extended in a situation where the tax had actually been paid.

Facts- The respondent/assessee claims that it is eligible for tax credit qua tax which, though payable in the country from where the income emanated, was not paid because of

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