Commissioner Of Income-Tax vs Dr. R.N. Jhanji on 29 August, 1988
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 80RRA being a part of the same scheme. If that is so done, the irresistible conclusion would be that no amount of tax paid on the total foreign income in the foreign country is entitled to relief under section 91(1) of the Income-tax Act. Only fifty per cent. of the total foreign income is liable to be excluded.