Wipro rebuts Yokogawa, context different, inapplicable to tax credit u/s 90(1)(a)(ii)
Rebutting Revenue Counsel’s reliance on Yokogawa ruling, Senior Advocate N. Venkatraman for Wipro contends Yokogawa would not apply to S.90(1)(a)(ii) scenario; Highlights S.90(1)(a)(ii) specifically uses the expression ‘income tax chargeable’ and Yokogawa ruling was rendered in the context of S.14 which uses the expression ‘charge of income-tax’; Further, argues that Yokogawa ruling did not deal with a situation involving S.4, 5 r.w. S.2(45), as judgment clearly ...
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