https://www.taxtmi.com/caselaws?id=69582 In computing surtax under the Companies (Profits) Surtax Act, 1964, chargeable profits had to be determined first under the Act and its First Schedule, including Rule 2(ii), before any treaty relief was considered. Section 24A and the India-Singapore double taxation agreement operated in distinct fields: Article 2 treated income-tax and surtax as Indian tax, while Article 24(2)(a) allowed credit for Singapore tax against Indian tax. The omission to apply Rule 2(ii) in the chargeable profits computation had to be corrected, after which the surtax liability could be properly ascertained without treating treaty relief as reduced or duplicated. en-us Thu, 20 Apr 1995 00:00:00 +0530 Thu, 07 Apr 2011 17:38:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69582 In computing surtax under the Companies (Profits) Surtax Act, 1964, chargeable profits had to be determined first under the Act and its First Schedule, including Rule 2(ii), before any treaty relief was considered. Section 24A and the India-Singapore double taxation agreement operated in distinct fields: Article 2 treated income-tax and surtax as Indian tax, while Article 24(2)(a) allowed credit for Singapore tax against Indian tax. The omission to apply Rule 2(ii) in the chargeable profits computation had to be corrected, after which the surtax liability could be properly ascertained without treating treaty relief as reduced or duplicated. Case-Laws Income Tax Thu, 20 Apr 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69582