In a recent decision, the Delhi High Court ruled on whether a decision of the Income Tax Appellate Tribunal was correct in finding that an India recipient of dividends exempt from tax in Oman may claim a sparing credit as provided in the 1997 India-Oman tax treaty. The case involved India-based Krishak Bharati Cooperative Limited, which received Oman-source dividends through its Oman PE as a result of its 25% stake in Oman India Fertilizer Company S.A.O.C., a joint venture with Oman Oil Company S.A.O.C. In receiving the exempt dividends, Krishak Bharati claimed a foreign tax credit (FTC) based on the...