https://www.taxtmi.com/caselaws?id=12197 The High Court ruled in favor of the assessee, holding that relief under section 91(1) of the Income-tax Act should be calculated on a country-wise basis, not through aggregation of income from all foreign branches. The court emphasized the need for a specific approach to prevent double taxation and ensure accurate relief calculation based on income from individual countries. The judgment rejected the Department's argument for aggregation, highlighting the potential inconsistencies and defeating the purpose of the relief provision. en-us Fri, 22 Nov 2002 00:00:00 +0530 Fri, 19 Feb 2010 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12197 The High Court ruled in favor of the assessee, holding that relief under section 91(1) of the Income-tax Act should be calculated on a country-wise basis, not through aggregation of income from all foreign branches. The court emphasized the need for a specific approach to prevent double taxation and ensure accurate relief calculation based on income from individual countries. The judgment rejected the Department's argument for aggregation, highlighting the potential inconsistencies and defeating the purpose of the relief provision. Case-Laws Income Tax Fri, 22 Nov 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12197