1993 (10) TMI 27

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..... its order dated September 25, 1982, in respect of the assessment years 1976-77 and 1977-78 under section 256(1) of the Income-tax Act, 1961 : "Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in holding that the assessee was entitled for credit for the entire amount of tax deducted at source in Iran under section 91(1) of the Income-tax .....

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..... ax paid on the foreign income which was taxed in India. On the basis of this, the court came to the conclusion that the assessee is entitled to double taxation relief under section 91(1) only of the remission of tax paid on 50 per cent. of the total foreign income. In CIT v. Dr. R. S. Bhatt [1990] 185 ITR 592 (Raj), the judgment of this court in CIT v. Dr. R. N. Jhanji [1990] 185 ITR 586 (Raj) w .....

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