Elimination of double taxation: reciprocal foreign tax credit rules permit deduction for tax paid abroad, subject to attributable income limits. Portugal allows a deduction from Portuguese tax for income-tax paid in India on income taxable in India under the Convention, limited to the portion of Portuguese tax attributable to that income; India provides reciprocal relief by allowing a deduction from Indian tax for tax paid in Portugal on income taxable in Portugal under the Convention, similarly limited to the part of Indian tax attributable to that income.
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Provisions expressly mentioned in the judgment/order text.
Elimination of double taxation: reciprocal foreign tax credit rules permit deduction for tax paid abroad, subject to attributable income limits.
Portugal allows a deduction from Portuguese tax for income-tax paid in India on income taxable in India under the Convention, limited to the portion of Portuguese tax attributable to that income; India provides reciprocal relief by allowing a deduction from Indian tax for tax paid in Portugal on income taxable in Portugal under the Convention, similarly limited to the part of Indian tax attributable to that income.
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