Double taxation relief: treaty-based exemption or credit and domestic foreign tax credit mechanisms for residents. Double taxation relief is provided as bilateral relief under Sections 90 and 90A-via the exemption method (Article 23A) or the tax credit method (Article 23B)-and as unilateral relief under Section 91, which grants foreign tax credit where no DTAA exists; India has DTAAs with over one hundred countries and chiefly follows the credit method, with Foreign Tax Credit Rules under Rule 128 of the Income Tax Rules, 1962 setting out credit mechanics.
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Provisions expressly mentioned in the judgment/order text.
Double taxation relief: treaty-based exemption or credit and domestic foreign tax credit mechanisms for residents.
Double taxation relief is provided as bilateral relief under Sections 90 and 90A-via the exemption method (Article 23A) or the tax credit method (Article 23B)-and as unilateral relief under Section 91, which grants foreign tax credit where no DTAA exists; India has DTAAs with over one hundred countries and chiefly follows the credit method, with Foreign Tax Credit Rules under Rule 128 of the Income Tax Rules, 1962 setting out credit mechanics.
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