Topic

Treaty Relief

1 articleLatest April 2026
Section 90/90A IT Act | Foreign Tax Credit Cannot Be Denied If Full Evidence of Foreign Tax Paid Is Later Submitted : ITAT Mumbai
Case Law Analysis
|Income Tax Appellate Tribunal

Section 90/90A IT Act | Foreign Tax Credit Cannot Be Denied If Full Evidence of Foreign Tax Paid Is Later Submitted : ITAT Mumbai

The ITAT Mumbai ruled that denying foreign tax credit under Section 90/90A solely for delayed submission of US tax documents violates treaty relief principles, provided the taxpayer furnishes complete, verifiable evidence of foreign tax paid before final assessment. This sets a vital precedent for NRIs and cross-border earners facing procedural delays in foreign tax documentation.