The Income Tax Appellate Tribunal of Hyderabad issued a decision on 6 October 2021 in a case concerning whether a deduction may be claimed in respect of foreign tax paid exceeding a partial credit. The case involved a wholly owned subsidiary (the assessee) in India of a U.S. software company that had paid foreign tax totaling INR 5,561,306 through withholding in Indonesia, Malaysia, and Rwanda. In respect of the foreign tax paid, a credit for the full amount was claimed, but the assessing off…