S. 90 : Double taxation relief-Credit for tax paid abroad-Foreign tax credit-Sales of units eligible for deduction under S. 10AA-DTAA-Taxes paid Australia and Canada, benefit of tax paid in Australia and Canada cannot be allowed against Indian income-tax-Taxes paid by the assessee in Japan, Switzerland and Malaysia are eligible for credit DTAA-India-Australia-Belgium-Canada-Japan-Malaysia, Switzerland [S. 10AA,37(1), 90(1)(a)(i), 90(1)(a)(ii), Art, 24, 23, 23, 23, 24, 23]
Capgemini Technology Services India Ltd. v. Dy. CIT (2022) 220 TTJ 409 (Pune) (Trib)