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    <title>1975 (12) TMI 65 - GUJARAT High Court</title>
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    <description>The court held in favor of the assessee-company, determining that they were entitled to double income-tax relief under Section 91 of the Income-tax Act, 1961, for dividend income received from UK companies. The court found that the conditions for granting double taxation relief were met, including the interpretation that tax deducted at source by foreign companies constituted &quot;income-tax paid&quot; under the law. The court applied precedent from a prior case to support its decision, emphasizing a liberal construction of Section 91 in favor of the assessee when conditions are satisfied. The revenue was directed to pay the costs of the reference to the assessee.</description>
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    <pubDate>Mon, 22 Dec 1975 00:00:00 +0530</pubDate>
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      <title>1975 (12) TMI 65 - GUJARAT High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=39313</link>
      <description>The court held in favor of the assessee-company, determining that they were entitled to double income-tax relief under Section 91 of the Income-tax Act, 1961, for dividend income received from UK companies. The court found that the conditions for granting double taxation relief were met, including the interpretation that tax deducted at source by foreign companies constituted &quot;income-tax paid&quot; under the law. The court applied precedent from a prior case to support its decision, emphasizing a liberal construction of Section 91 in favor of the assessee when conditions are satisfied. The revenue was directed to pay the costs of the reference to the assessee.</description>
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      <pubDate>Mon, 22 Dec 1975 00:00:00 +0530</pubDate>
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