Computation of undisclosed foreign income limits deductions and allows reduction for previously taxed foreign income when evidenced. Computation of undisclosed foreign income disallows any deduction, allowance or loss set off when determining total undisclosed foreign income and asset. A reduction from the asset's value is permitted only if the assessee furnishes evidence satisfactory to the Assessing Officer that the asset was acquired from income already assessed or assessable to tax. For immovable property abroad, the deductible amount is the proportion of the asset's value (on the first day of the financial year when noticed) that corresponds to the ratio of assessable or assessed foreign income to the total cost of the asset.
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Provisions expressly mentioned in the judgment/order text.
Computation of undisclosed foreign income limits deductions and allows reduction for previously taxed foreign income when evidenced.
Computation of undisclosed foreign income disallows any deduction, allowance or loss set off when determining total undisclosed foreign income and asset. A reduction from the asset's value is permitted only if the assessee furnishes evidence satisfactory to the Assessing Officer that the asset was acquired from income already assessed or assessable to tax. For immovable property abroad, the deductible amount is the proportion of the asset's value (on the first day of the financial year when noticed) that corresponds to the ratio of assessable or assessed foreign income to the total cost of the asset.
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