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    <title>2016 (11) TMI 1360 - ITAT DELHI</title>
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    <description>Revision under section 263 was held unsustainable where the Assessing Officer had made enquiries and adopted a plausible view. On deemed tax credit for dividend income from Oman under article 25(4) read with section 90, the treaty provision was treated as a tax-sparing measure, so credit was allowable even though no tax was actually paid in Oman; the revisional authority could not substitute another interpretation. On capitalisation of interest under section 36(1)(iii), the record showed examination of borrowings, fixed assets, capital work-in-progress and accounting treatment, and the assessee had sufficient interest-free funds and internal accruals. As both issues had been properly examined, the revisional order was unsustainable.</description>
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      <title>2016 (11) TMI 1360 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=335342</link>
      <description>Revision under section 263 was held unsustainable where the Assessing Officer had made enquiries and adopted a plausible view. On deemed tax credit for dividend income from Oman under article 25(4) read with section 90, the treaty provision was treated as a tax-sparing measure, so credit was allowable even though no tax was actually paid in Oman; the revisional authority could not substitute another interpretation. On capitalisation of interest under section 36(1)(iii), the record showed examination of borrowings, fixed assets, capital work-in-progress and accounting treatment, and the assessee had sufficient interest-free funds and internal accruals. As both issues had been properly examined, the revisional order was unsustainable.</description>
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      <pubDate>Mon, 19 Sep 2016 00:00:00 +0530</pubDate>
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