Foreign Tax Credit eligible for taxes withheld in Japan: ITAT Mumbai

Amarchand Mangaldas & Suresh A Shroff & Co. Vs ACIT (ITAT Mumbai) ITAT Mumbai held that services rendered by the appellant is taxable in Japan in accordance to Article 12 of the India-Japan DTAA hence Foreign Tax Credit ought to have been granted to Appellant for taxes withheld in Japan. Facts- The present appeal is preferred by the appellant. Notably, AO, on perusal of the return of the income, noticed that the assessee has claimed relief u/s 90 of the Act for the income received for services rendered in Japan. Since, the receipt was in the nature of independent personal services, it ...