The Delhi Income Tax Appellate Tribunal recently issued a decision on the conditions that must be met for an Indian resident recipient of dividends to claim a tax sparing credit under the 1985 income tax treaty with Thailand (since replaced by 2015 treaty). The case involved India-based Polyplex Corporation Ltd., which during the years of assessment 2010-11 to 2013-14 received dividend payments from a Thai subsidiary that were exempt from Thai tax based on the provisions of the Thai Investment Promotion Act. In respect of the dividend income, Polyplex claimed a tax sparing credit according to the provisions of Article...