Double taxation elimination: resident state must allow deduction for foreign tax paid, subject to attribution and incentive adjustments.

A resident State shall allow as a deduction from domestic tax an amount equal to income tax paid in the other Contracting State, limited to the portion of domestic tax attributable to that income; for India the deemed foreign tax includes tax forgone due to tax incentives; exempted income may still be taken into account when calculating tax on the resident's remaining income.

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