Foreign tax credit would be allowed even if income is exempt in India

IT/ILT : Income covered under section 10A is "chargeable to tax" under section 4 and is includible in total income under section 5 but no tax is charged because of the exemption given u/s10A only for a period of 10 years. The exemption u/s 10A does not make the income not leviable to income tax. Therefore, the case falls u/s 90(1)(a)(ii). Assessee is entitled to the said benefit by virtue of section 91 even where India has no agreement with the States where the tax is levied on the income of the