Benefit of tax credit under Article 23 of Indo-Thai DTAA extended only when tax actually paid
Delhi High Court held that tax credit could not be extended to the assessee, because it had not paid tax in Thailand, i.e., that benefit under Article 23 of the Indo-Thai DTAA could only be extended in a situation where the tax had actually been paid.
Kunal Sharma Delhi High Court Polyplex Thailand Public Limited Company Krishak Bharti Cooperative Polyplex Corporation Ltd High Court
Source: taxguru.in