Elimination of double taxation: credit by India and exemption by Norway with specific deeming and limits for relief. Article 25 sets bilateral relief: India allows a credit/deduction against Indian income or capital tax for tax paid in Norway up to the Indian tax attributable to the foreign income or capital, with company surtax treated second. Norway generally exempts income or capital taxed in India but allows deductions for Indian tax on specified income items, limited to the Norwegian tax attributable to those items. Deeming rules treat certain Indian exemptions as paid tax for credit purposes; interest is deemed taxed at no less than fifteen per cent for deduction purposes. The deeming provisions and minimum interest rate apply for the first ten years, and exempted income may be taken into account in computing tax rates on remaining income.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Elimination of double taxation: credit by India and exemption by Norway with specific deeming and limits for relief.
Article 25 sets bilateral relief: India allows a credit/deduction against Indian income or capital tax for tax paid in Norway up to the Indian tax attributable to the foreign income or capital, with company surtax treated second. Norway generally exempts income or capital taxed in India but allows deductions for Indian tax on specified income items, limited to the Norwegian tax attributable to those items. Deeming rules treat certain Indian exemptions as paid tax for credit purposes; interest is deemed taxed at no less than fifteen per cent for deduction purposes. The deeming provisions and minimum interest rate apply for the first ten years, and exempted income may be taken into account in computing tax rates on remaining income.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
