Denial of Foreign tax credit - If the finding of lower authority ...
Foreign Tax Credit Granted: Offshore Transaction Income with US Source Not Taxable Under Effective Management Rule.
September 2, 2023
Case Laws Income Tax AT
Denial of Foreign tax credit - If the finding of lower authority regarding place of effective management is presumed to be correct, in that case, no tax could be charged as the transaction took place off shores and income was generated in USA - Benefit of FTC allowed - AT
View Source