Unilateral relief for double taxation requires computing foreign tax as a percentage in foreign currency and applying the lower rate. Unilateral relief under Section 91 is to be allowed at the lower of the Indian tax rate or the rate of tax in the foreign country, with the foreign rate computed by expressing both the income assessed abroad and the tax paid there in the foreign currency and calculating tax as a percentage of that income; conversion into Indian rupees for rate computation is not permitted because exchange rate fluctuations can distort the correct foreign-country tax rate.
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Provisions expressly mentioned in the judgment/order text.
Unilateral relief for double taxation requires computing foreign tax as a percentage in foreign currency and applying the lower rate.
Unilateral relief under Section 91 is to be allowed at the lower of the Indian tax rate or the rate of tax in the foreign country, with the foreign rate computed by expressing both the income assessed abroad and the tax paid there in the foreign currency and calculating tax as a percentage of that income; conversion into Indian rupees for rate computation is not permitted because exchange rate fluctuations can distort the correct foreign-country tax rate.
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