Section 160 - Countries with which no agreement exists.

Double taxation relief: deduction against Indian tax where foreign tax paid in countries without an agreement reduces Indian tax liability.

Residents who pay income-tax in countries without a double taxation agreement are entitled to a deduction from Indian income-tax on the doubly taxed foreign income, calculated at the lower of the Indian rate of tax and the foreign rate of tax (or the Indian rate if both rates are equal). The same deduction entitlement and comparative-rate calculation applies to non-residents taxed on a share of income from a firm resident in India when that share includes foreign-sourced income taxed in such countries. Key definitional rules for computing Indian and foreign rates and the scope of 'income-tax' are provided.