https://www.taxtmi.com/caselaws?id=66839 A resident assessee's salary earned in France was includible in total income for rate purposes under the Income-tax Act, 1961. Section 5 brought foreign-source income of a resident within total income, and section 110 permitted income on which no tax was payable to be aggregated for computing the applicable rate on remaining income. The India-France double taxation agreement did not exclude the salary from total income; it only prevented taxation in the contracting state where the services were not rendered. Article XIX preserved domestic tax law, and Article XIX(4) expressly allowed such income to be taken into account for rate calculation. The foreign salary was therefore rightly included for rate purposes. en-us Thu, 21 Apr 1983 00:00:00 +0530 Mon, 07 Mar 2011 16:49:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=66839 A resident assessee's salary earned in France was includible in total income for rate purposes under the Income-tax Act, 1961. Section 5 brought foreign-source income of a resident within total income, and section 110 permitted income on which no tax was payable to be aggregated for computing the applicable rate on remaining income. The India-France double taxation agreement did not exclude the salary from total income; it only prevented taxation in the contracting state where the services were not rendered. Article XIX preserved domestic tax law, and Article XIX(4) expressly allowed such income to be taken into account for rate calculation. The foreign salary was therefore rightly included for rate purposes. Case-Laws Income Tax Thu, 21 Apr 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=66839