Double taxation agreement inoperative; post-conflict assessments governed by relief under section 91 for India-Pakistan/Bangladesh cases. The 1947 Agreement for avoidance of double taxation between India and Pakistan is no longer operative for assessment year 1972-73 and subsequent years in relation to Pakistan and Bangladesh; for those years residents of India liable to tax in Pakistan or Bangladesh are entitled to relief only under section 91. The 1947 Agreement continues to apply to assessment years prior to 1972-73, including reopened assessments, with its Schedule and abatement mechanisms remaining applicable for those earlier years.
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.
Double taxation agreement inoperative; post-conflict assessments governed by relief under section 91 for India-Pakistan/Bangladesh cases.
The 1947 Agreement for avoidance of double taxation between India and Pakistan is no longer operative for assessment year 1972-73 and subsequent years in relation to Pakistan and Bangladesh; for those years residents of India liable to tax in Pakistan or Bangladesh are entitled to relief only under section 91. The 1947 Agreement continues to apply to assessment years prior to 1972-73, including reopened assessments, with its Schedule and abatement mechanisms remaining applicable for those earlier years.
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