https://www.taxtmi.com/caselaws?id=59403 The Tribunal held that the Commissioner (Appeals) erred in granting full double taxation relief under section 91 for foreign income included in the total income of an Indian resident assessee. The relief was limited to 50% due to the provisions of section 80-O, as only the portion of foreign income subjected to tax in India is eligible for relief. The decision emphasized that relief is based on total income computation, not specific heads of income, reinforcing the principle that relief under section 91 is granted for foreign income included in the total income and subjected to tax in India. en-us Thu, 26 Apr 2001 00:00:00 +0530 Wed, 29 Dec 2010 14:57:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59403 The Tribunal held that the Commissioner (Appeals) erred in granting full double taxation relief under section 91 for foreign income included in the total income of an Indian resident assessee. The relief was limited to 50% due to the provisions of section 80-O, as only the portion of foreign income subjected to tax in India is eligible for relief. The decision emphasized that relief is based on total income computation, not specific heads of income, reinforcing the principle that relief under section 91 is granted for foreign income included in the total income and subjected to tax in India. Case-Laws Income Tax Thu, 26 Apr 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59403