Section 91 - Countries with which no agreement exists

Double taxation relief: deduction allowed for residents paying foreign tax in treaty absent countries, limited to the lower tax rate.

Residents paying tax in countries lacking a double taxation agreement may deduct from Indian income-tax a sum on foreign income equal to the lower of the Indian rate of tax or the foreign country's rate of tax; similar relief applies to non-resident partners assessed on a share of a registered Indian firm's foreign income. A separate rule limits deduction for Pakistan agricultural tax to the tax paid or an amount computed at the Indian rate of tax, whichever is less. The section also defines 'Indian income-tax', the method to compute the Indian rate of tax, and the composition of the foreign rate of tax.