Elimination of double taxation: deduction of foreign tax paid from domestic tax, limited to income attributable to that source. Each Contracting State permits a deduction from domestic income and capital tax for tax paid in the other State on the same income or capital, limited so the deduction does not exceed the portion of domestic tax attributable to that income or capital; India may also take exempted income or capital into account when computing tax on the remaining base.
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Provisions expressly mentioned in the judgment/order text.
Elimination of double taxation: deduction of foreign tax paid from domestic tax, limited to income attributable to that source.
Each Contracting State permits a deduction from domestic income and capital tax for tax paid in the other State on the same income or capital, limited so the deduction does not exceed the portion of domestic tax attributable to that income or capital; India may also take exempted income or capital into account when computing tax on the remaining base.
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