Foreign tax credit available even on income not subjected to tax in India except foreign tax paid in Finland & Canada

Tata Consultancy Services Ltd. Vs Addl. CIT (ITAT Mumbai)

As could be seen, while the Assessing Officer has disallowed assessee’s claim of foreign tax credit in respect of income exempt under section 10A/10AA of the Act on the reasoning that only such income which is subjected to tax in both the countries would qualify for tax credit, learned Commissioner (Appeals) has restricted the relief of foreign tax credit only in respect of tax paid in USA even in respect of income which is exempt under section 10A/10AA of the A

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