Tax on foreign dividends: specified foreign company dividends attract a separate fixed-rate tax plus tax on remaining income. Where an Indian company's total income includes dividends from a specified foreign company, tax on such dividends is the aggregate of a separate tax at a fixed rate on the dividend amount and the income-tax that the assessee would have been chargeable with had total income been reduced by that dividend; no deduction or allowance is permitted against that dividend income. 'Dividends' follows section 2(22) excluding sub-clause (e), and 'specified foreign company' means a foreign company with at least twenty-six percent equity held by the Indian company.