1996 (7) TMI 85

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....ax Act, 1961, and the following two questions of law have been referred by the Tribunal for answer by this court : " (i) Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that tax deducted at source outside India from foreign dividend and interest income, was not part of the total income and, thus, not assessable in the hands of the assessee unde....

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....bjection that the net amount and not the gross amount should have been included in their respective total income. The appeal was accepted by the Commissioner of Income-tax (Appeals). Aggrieved by the order of the Commissioner of Income-tax (Appeals), the Revenue filed appeals before the Tribunal and the Tribunal upheld the stand of the assessees that only the net income and not the gross income wa....