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2018 (10) TMI 1802 - HC - Income TaxRevision u/s 263 - tax credit deemed to be paid in Oman - HELD THAT:- The contention of the Revenue that there was material change in view of the reduction of tax rate applicable to the respondent-assessee in Oman is inconsequential and misconceived. The assessing officer in his original order dated 27.03.2014 for the present year had allowed and given rebate of tax paid in Oman at the rate of 12% and not at the rate of 30%. Accordingly, the respondent-assessee was given tax credit of ₹ 17,37,09,837/- out of the total dividend paid in Oman of ₹ 144,75,81,978/-. Thus, the assessing officer had taken notice of the reduction of rate of tax and tax credit was only given for the tax paid in Oman. Change in tax rates/slab, therefore, would not make any difference; nor would it negate the ratio of the decision dated 02.08.2017 passed by the Division Bench of this Court [2017 (8) TMI 422 - DELHI HIGH COURT] pertaining to the assessment year 2010-11. The ratio of the order would accordingly apply. No substantial question of law
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