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    <title>1978 (5) TMI 2 - Supreme Court</title>
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    <description>Relief under section 49D of the Indian Income-tax Act, 1922 required proof that income accrued outside the taxable territories and had suffered foreign tax by deduction or otherwise under foreign law. Dividend income from U.K. companies, shown by warrants to have borne U.K. standard-rate tax, was treated as income on which tax had been paid in the foreign country, even though the shareholder was not separately assessed there. The foreign tax rate was ascertainable, and the statutory expression was read as covering income subjected to tax abroad. On that basis, the assessee satisfied section 49D and was entitled to relief.</description>
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    <pubDate>Tue, 02 May 1978 00:00:00 +0530</pubDate>
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      <title>1978 (5) TMI 2 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=5176</link>
      <description>Relief under section 49D of the Indian Income-tax Act, 1922 required proof that income accrued outside the taxable territories and had suffered foreign tax by deduction or otherwise under foreign law. Dividend income from U.K. companies, shown by warrants to have borne U.K. standard-rate tax, was treated as income on which tax had been paid in the foreign country, even though the shareholder was not separately assessed there. The foreign tax rate was ascertainable, and the statutory expression was read as covering income subjected to tax abroad. On that basis, the assessee satisfied section 49D and was entitled to relief.</description>
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      <pubDate>Tue, 02 May 1978 00:00:00 +0530</pubDate>
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