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1993 (10) TMI 27 - RAJASTHAN HIGH COURTExtract: .......the entire amount of tax deducted at source in Iran under section 91(1) of the Income-tax Act, 1961, and not in proportion to the income included in the total income of the assessee after considering the provisions of section 80RRA of the Income-tax Act, 1961. Accordingly, the reference is answered in favour of the Revenue and against the assessee.
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