Big victory for Wipro, Karnataka HC grants Foreign Tax Credit to tax holiday entities

Mar 19,2015

Karnataka HC delivers significant verdict on foreign tax credits to Indian IT company in tax holiday situations; Allows foreign tax credit (‘FTC’) u/s 90 to Wipro (enjoying Sec 10A tax holiday) on taxes paid abroad; HC holds that Sec 90(1)(a)(i) and (ii) cannot be interpreted to mean as obligating an actual payment of tax in both taxing jurisdictions for grant of foreign tax credit; HC also allows credit u/s 91 for State taxes paid abroad


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