Double taxation relief: residence-based tax credit or deduction limits cross-border tax on income, with incentive treatment conditions. Residents of Russia obtain relief for income taxable in India by a tax credit limited to the Russian tax on that income as computed under Russian law; residents of India obtain relief for income taxable in Russia by a deduction from Indian tax equal to tax paid in Russia, limited to the portion of Indian tax attributable to that income. Tax reduced or exempted under domestic incentive provisions is deemed tax paid for relief purposes to the extent it applies to qualifying profits from specified activities carried out within the State, subject to a time-limited application and possible extension by competent authorities.
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Provisions expressly mentioned in the judgment/order text.
Double taxation relief: residence-based tax credit or deduction limits cross-border tax on income, with incentive treatment conditions.
Residents of Russia obtain relief for income taxable in India by a tax credit limited to the Russian tax on that income as computed under Russian law; residents of India obtain relief for income taxable in Russia by a deduction from Indian tax equal to tax paid in Russia, limited to the portion of Indian tax attributable to that income. Tax reduced or exempted under domestic incentive provisions is deemed tax paid for relief purposes to the extent it applies to qualifying profits from specified activities carried out within the State, subject to a time-limited application and possible extension by competent authorities.
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