Elimination of double taxation: bilateral tax credit and deemed tax rules prevent double taxation while permitting exemption with progression. Elimination of double taxation is effected by a bilateral credit mechanism: India allows residents a deduction from Indian tax for Syrian income-tax paid, limited to the Indian tax attributable to that income (with company credits applied first against income-tax and then surtax); similarly, Syria allows residents a deduction for Indian income-tax paid, limited to Syrian tax attributable to that income. 'Income-tax paid' in each State is deemed to include amounts forgone under specified domestic development-related exemptions or deductions and subsequent agreed measures that remain substantially unchanged. Exemption with progression may be applied where income is exempt under the Agreement.
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Provisions expressly mentioned in the judgment/order text.
Elimination of double taxation: bilateral tax credit and deemed tax rules prevent double taxation while permitting exemption with progression.
Elimination of double taxation is effected by a bilateral credit mechanism: India allows residents a deduction from Indian tax for Syrian income-tax paid, limited to the Indian tax attributable to that income (with company credits applied first against income-tax and then surtax); similarly, Syria allows residents a deduction for Indian income-tax paid, limited to Syrian tax attributable to that income. "Income-tax paid" in each State is deemed to include amounts forgone under specified domestic development-related exemptions or deductions and subsequent agreed measures that remain substantially unchanged. Exemption with progression may be applied where income is exempt under the Agreement.
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