Section 91 & Rule 128: Including 'Other Income' in Net Profit for Foreign Income Deduction from Ghana in Indian Tax.

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....Deduction u/s 91 r.w.r 128 - income from foreign country - for the purpose of computing the net profit ratio of total income of the assessee in India which is used as the basis for arriving at the net income of Ghana should include ‘other income’. We have also held that the ‘effective Indian rate of tax’ should include surcharge and education cess i.e. 20.01%. The calculation of deduction u/s.91 as done in the above table is in accordance with our views expressed in the foregoing paragraphs and is a reasonable basis of arriving at the effective rate of tax for Ghana. Hence we are of the considered view that it is reasonable to allow the deduction u/s.91 to the assessee. - AT....