https://www.taxtmi.com/caselaws?id=59730 Reassessment under Section 147 was upheld because it was issued within four years and the original assessment had not examined the Section 80-O computation issue, so the reopening was not barred as a mere change of opinion. Deduction under Section 80-O was held available only on the net amount received in convertible foreign exchange and brought into India, not on gross foreign consultancy receipts, as foreign tax deducted abroad did not satisfy the statutory receipt requirement. Treaty credit for Thai tax under Article 23 was allowed, but only up to the Indian tax attributable to the same income, consistent with the treaty ceiling. en-us Mon, 25 Aug 2008 00:00:00 +0530 Tue, 05 Nov 2013 11:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59730 Reassessment under Section 147 was upheld because it was issued within four years and the original assessment had not examined the Section 80-O computation issue, so the reopening was not barred as a mere change of opinion. Deduction under Section 80-O was held available only on the net amount received in convertible foreign exchange and brought into India, not on gross foreign consultancy receipts, as foreign tax deducted abroad did not satisfy the statutory receipt requirement. Treaty credit for Thai tax under Article 23 was allowed, but only up to the Indian tax attributable to the same income, consistent with the treaty ceiling. Case-Laws Income Tax Mon, 25 Aug 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59730