Revenue draws from Yokogawa ruling to deny FTC stating Sec 10A, an exemption-provision
Revenue Senior Counsel E. Indrakumar continued arguments before Karnataka HC on Wipro’s foreign tax credit (FTC) issue yesterday; Swings into focus the scheme of Sec 10A income that stands exempted and doesn’t form part of total income, drawing attention to the co-ordinate bench ruling in Yokogawa; Further re-iterates that FTC is not applicable even under India-US DTAA and Sec 90(1)(a)(ii) is prospective; Revenue Counsel to continue arguments today...
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