Elimination of double taxation permits a credit for foreign tax paid against domestic tax, subject to domestic limits. Elimination of double taxation is achieved by reciprocal foreign tax credits: India permits a deduction from Indian tax for income or capital tax paid in Georgia limited to the portion of Indian tax attributable to the income or capital taxable in Georgia, and may account for exempted items when computing tax on remaining income or capital. Georgia correspondingly permits deductions for Indian tax paid, limited to the tax that would have accrued under Georgian rules and rates, and may likewise consider exempted income or capital in computing tax on remaining items.
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Provisions expressly mentioned in the judgment/order text.
Elimination of double taxation permits a credit for foreign tax paid against domestic tax, subject to domestic limits.
Elimination of double taxation is achieved by reciprocal foreign tax credits: India permits a deduction from Indian tax for income or capital tax paid in Georgia limited to the portion of Indian tax attributable to the income or capital taxable in Georgia, and may account for exempted items when computing tax on remaining income or capital. Georgia correspondingly permits deductions for Indian tax paid, limited to the tax that would have accrued under Georgian rules and rates, and may likewise consider exempted income or capital in computing tax on remaining items.
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