CIT v. Dr. R.N. Jhanji

185 ITR 586High Court1990#23262 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 346,713 Indian tax judgments — from 2021 to 2025.

Sections most often in play

Section 10ASection 115JBSection 143(3)Section 244ASection 90Section 91Section 92CASection 254

Judgments citing CIT v. Dr. R.N. Jhanji

DCIT Circle 4(2), New Delhi vs. Canon India Pvt. Ltd., New Delhi

In the result, to sum up and conclude:

ITA 1038/DEL/2023[2005-06]Status: DisposedITAT Delhi10 Nov 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR
Section 10ASection 143(3)Section 254Section 92C

…ide the tax net in Yokogawa, foreign income neutralized by losses in Bank of India was treated as not subjected to Indian tax, thereby disentitling FTC. 18. The revenue's stand also finds support in the earlier High Court decisions in CIT v. Dr. R.N. Jhanji (185 ITR 586) and CIT v. M.A. Morris (210 ITR 284). In Dr. R.N. Jhanji, the Punjab & Haryana High Court held that double taxation relief under section 91 cannot exceed the Indian tax payable on the doubly taxed income. Similarly, in M.A. Morris, the Kerala High Court held that credit for taxes paid abroad is not available when no tax is payable in India on th…

Canon India Pvt. Ltd, Gurugram vs. Neac, Delhi

In the result, to sum up and conclude:

ITA 585/DEL/2021[2003-04]Status: DisposedITAT Delhi10 Nov 2025AY 2003-04

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR
Section 10ASection 143(3)Section 254Section 92C

…ide the tax net in Yokogawa, foreign income neutralized by losses in Bank of India was treated as not subjected to Indian tax, thereby disentitling FTC. 18. The revenue's stand also finds support in the earlier High Court decisions in CIT v. Dr. R.N. Jhanji (185 ITR 586) and CIT v. M.A. Morris (210 ITR 284). In Dr. R.N. Jhanji, the Punjab & Haryana High Court held that double taxation relief under section 91 cannot exceed the Indian tax payable on the doubly taxed income. Similarly, in M.A. Morris, the Kerala High Court held that credit for taxes paid abroad is not available when no tax is payable in India on th…

Bank of India, Mumbai vs. DCIT - 2(1)(1), Mumbai

In the result, the appeal is partly allowed for statistical purposes in the terms indicated above

ITA 869/MUM/2018[2012-13]Status: DisposedITAT Mumbai04 Mar 2021AY 2012-13
Section 250Section 90Section 90nSection 91

…Hon’ble Karnataka High Court, learned Departmental Representative submits that this decision overlooks, and does not even deal with, other Hon’ble High Court judgments in the case of CIT Vs M A Morris [(1994) 210 ITR 284 (AP)] and CIT Vs Dr R N Jhanji [(1990) 185 ITR 586 (Raj)]. On the first principles, this decision is clearly incorrect inasmuch as all the methods of eliminating the double taxation, i.e. exemption method, credit method or hybrid method, restrict the liability to tax in the source jurisdiction, but the relief sought in the present case goes well beyond that and would result in a refund of taxes b…

CIT v. Dr. R.N. Jhanji (185 ITR 586) — Cited in 3 Judgments | BharatTax