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ITAT allows foreign tax credit to ‘TCS’ even in respect of income on which it has not paid tax in India

November 6, 2019[2019] 111 42 (Mumbai)

INTERNATIONAL TAXATION: Any sum eligible for relief of tax either under section 90 or 91 would not be allowable as deduction under section 40(a)(ii)

INTERNATIONAL TAXATION: Where assessee made payment for acquisition of software for trading purpose, only if assessee had transferred any license or copyright, payment so made by assessee towards acquiring software products would be royalty

INTERNATIONAL TAXATION: Foreign tax credit would be available to assessee an Indian company having several overseas branches across globe in all cases except foreign tax paid in Finland and Canada

INTERNATIONAL TAXATION: Where assessee in respect of its export business made commission payments to its non-resident agents who had rendered services in their respective countries and did not have either any business connection or any PE in India, commission paid to non-resident agents would not be chargeable to tax in India at their hands

INTERNATIONAL TAXATION: While computing amount of deduction under section 10A, foreign currency expenditure has to be reduced both from export turnover as well as total turnover

TRANSFER PRICING: Where in transfer pricing proceedings, TPO made addition to assessee's ALP on ground that assessee had provided loan facilities to its AEs without charging any interest, however, primary contention of assessee that advance made to AEs was in nature of quasi equity and fell within shareholder's activity had not been properly addressed, matter was to be remanded back for de nove adjudication

TRANSFER PRICING: After introduction of Explanation-(i)(c) to section 92B, with retrospective effect from 1-4-2002, provision of guarantee to AEs has to be considered as an international transaction
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