Arindam Lahiri’s Post

Very crisp and informative @arindam The current SC ruling in case of Nestle SA and others on MFN clause may also sound relevant here. Since most nations in EU do not tax dividend owing to participation exemption. So the taxes withheld in the subsidiary home country like India becomes a cost with no recourse to claim FTC, not even an expense claim (unlike US which has provisions for claiming FTC as an expense at the option of tax payer under certain circumstances)

Arindam, the challenge in FTC utilisation is not addressed by the authorities considering the Businessman's issues. Let's hope that this issue is addressed at the earliest. Considering the fact that forex earning is so important for any economy's good health, a global consensus is desired to have a justified resolution. You have highlighted the problem very candidly.

This is the reflection of Juxtaposition of Truculent behaviour towards honest Assessee. This putting the kibosh on the real profitability and the modern cross border trade is deprived of the real profit. The heavy withholding of neighbours really put the Indian Corporate houses on Fix. I wish the Agency shouldn't take a Myopic view and allow justice.