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Ground raised by the assessee is that on the facts and in law and in the circumstances of the case, the ld AO erred in not following the Directions of the Hon'ble DRP and making in addition of Rs. 1,17,57,533/-, being provision for bad debts and doubtful debts written back during the year, without appreciating the fact that the amount of such provisions were already offered to tax in the earlier AYs.

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Section 9 of the Income Tax Act, 1961—Income—Income deemed to accrue or arise in India - Foreign tax credit (FTC) may be allowed to the assessee in accordance to law, therefore, direction was given to assessing officer to examine the correctness of the assessee's claim for foreign tax credit (FTC), as per India USA-Treaty, and allow the claim of the assessee in accordance to law - PRICEWATERHOUSECOOPERS (P.) LTD. V/s ACIT - [2020] 183 ITD 354 (ITAT-KOLKATA)