The Bangalore Income Tax Appellate Tribunal (ITAT) issued a decision on 13 January 2021 concerning foreign tax credits on foreign source income derived by a resident of India, considering applicable tax treaties.
The case involved an Indian company, ITTIAM Systems Pvt. Ltd., which specializes in signal processing application and media processing and communication and received royalty and license fee payments subject to withholding in Germany, Japan, South Korea, and the United States. In its…