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    <title>1993 (9) TMI 158 - ITAT DELHI-B</title>
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    <description>Income from construction activities in Libya was treated as taxable in India as well as in Libya under the applicable double taxation agreement, because the treaty governed business profits through its permanent establishment rules and provided relief only by way of credit for foreign tax paid. The treaty did not exclude the income from Indian taxation merely because it was also taxed in Libya. Weighted deduction was also denied on the Libyan project expenditure, as the relevant provision covered export promotion and similar qualifying outlays, not the cost of carrying out the construction work itself. The assessee therefore received only treaty tax credit relief, and the weighted deduction claim failed.</description>
    <language>en-us</language>
    <pubDate>Thu, 30 Sep 1993 00:00:00 +0530</pubDate>
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      <title>1993 (9) TMI 158 - ITAT DELHI-B</title>
      <link>https://www.taxtmi.com/caselaws?id=63507</link>
      <description>Income from construction activities in Libya was treated as taxable in India as well as in Libya under the applicable double taxation agreement, because the treaty governed business profits through its permanent establishment rules and provided relief only by way of credit for foreign tax paid. The treaty did not exclude the income from Indian taxation merely because it was also taxed in Libya. Weighted deduction was also denied on the Libyan project expenditure, as the relevant provision covered export promotion and similar qualifying outlays, not the cost of carrying out the construction work itself. The assessee therefore received only treaty tax credit relief, and the weighted deduction claim failed.</description>
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      <pubDate>Thu, 30 Sep 1993 00:00:00 +0530</pubDate>
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