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    <description>Income earned through foreign branches in Singapore and Sri Lanka was held includible in the resident assessee&#039;s Indian total income, with relief available under the DTAA through the foreign tax credit mechanism rather than exemption. The foreign currency fluctuation reserve issue was remanded for de novo adjudication because the assessee had not been given a proper opportunity to explain the reserve, and the matter had to be reconsidered in accordance with natural justice. Education cess was held not deductible as business expenditure under the applicable statutory framework, and the disallowance was sustained.</description>
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      <description>Income earned through foreign branches in Singapore and Sri Lanka was held includible in the resident assessee&#039;s Indian total income, with relief available under the DTAA through the foreign tax credit mechanism rather than exemption. The foreign currency fluctuation reserve issue was remanded for de novo adjudication because the assessee had not been given a proper opportunity to explain the reserve, and the matter had to be reconsidered in accordance with natural justice. Education cess was held not deductible as business expenditure under the applicable statutory framework, and the disallowance was sustained.</description>
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