Assessee (Public Sector Bank) earned income profits/dividend on its operations in several countries (both treaty and non-treaty jurisdictions) through its branches, subjected to payment of tax in treaty jurisdictions, non-treaty jurisdictions and withholding dividend income in different jurisdictions, but incurred loss at global level.

Thus, assessee claimed that income tax paid by assessee to foreign tax jurisdictions should be refunded to assessee by Indian tax authorities.

 The claim of assessee was rejected both by Assessing Officer and Commissioner (Appeals)

 Full foreign tax credits cannot be inferred to be permissible as a matter of course and normal practice.

 Just because co-ordinate benches have subconsciously taken a stand that seems to be condoning, and in a way legitimizing, a contrary perception, even if that be so, one cannot, particularly after taking a closer look at situation, follow the same course.

When such huge national revenues, involving thousands of crores, are involved in this macro issue, one cannot afford to be superficial, or perfunctory, in approach.

Hence, assessee is declined foreign tax credits and, accordingly, it is held that the assessee is not entitled to seek a refund of that money from the Indian tax exchequer.

 On a separate note, nevertheless, claim of assessee that these taxes paid abroad will be allowed as a deduction in the computation of the business income of the assessee.