1990 (7) TMI 14

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.... question has been referred to the High Court for its opinion : "Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that the assessee was entitled to deduct the full amount of tax deducted at source by the Government of the foreign country from the tax payable on the said income in India ? " The dispute relates to the assessee's claim for....

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....f tax paid on fifty per cent. of the total foreign income. On a construction of section 91 (1) of the Income-tax Act, 1961, we find ourselves in agreement with the view taken in CIT v. Dr. R. N. Jhanji [1990] 185 ITR 586 (Raj). Section 91(1) has to be construed along with section 80 RRA being a part of the same scheme. If that is so done, the irresistible conclusion would be that no amount of t....