https://www.taxtmi.com/caselaws?id=69150 Treaty-based double taxation relief under the India-Singapore agreement was analysed with reference to the income actually subjected to tax in India, not the full gross royalty. Because only the balance remaining after section 80-O deduction was taxed in India, Singapore tax credit was confined to that net royalty amount and not the entire royalty income. The text also states that foreign tax credit could not be given on a priority basis against surtax liability, as the Companies (Profits) Surtax Act, 1964 followed its own computation framework and did not require treaty relief to be first adjusted against surtax. The Revenue's computation was upheld on both issues. en-us Fri, 19 Jan 2001 00:00:00 +0530 Mon, 13 Jun 2011 16:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69150 Treaty-based double taxation relief under the India-Singapore agreement was analysed with reference to the income actually subjected to tax in India, not the full gross royalty. Because only the balance remaining after section 80-O deduction was taxed in India, Singapore tax credit was confined to that net royalty amount and not the entire royalty income. The text also states that foreign tax credit could not be given on a priority basis against surtax liability, as the Companies (Profits) Surtax Act, 1964 followed its own computation framework and did not require treaty relief to be first adjusted against surtax. The Revenue's computation was upheld on both issues. Case-Laws Income Tax Fri, 19 Jan 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69150