Foreign Tax Credit Cannot Be Denied for Partial Overseas Return Filing: ITAT Mumbai

Vinay Dube Vs ITO (ITAT Mumbai) The appeal before the ITAT Mumbai arose from an order passed under Section 250 of the Income Tax Act, 1961 for Assessment Year 2023–24, concerning denial of foreign tax credit (FTC) claimed under Sections 90/90A. The assessee, an individual earning salary, capital gains, and other income in both India and the United States, filed a return declaring total income of ₹5.03 crore and claimed FTC of ₹84.16 lakh against foreign taxes of ₹1.96 crore paid in the USA. During assessment, the Assessing Officer (AO) sought evidence of foreign taxes paid and the basi...