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    <title>1972 (10) TMI 6 - Supreme Court</title>
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    <description>Section 49D of the Indian Income-tax Act, 1922 was construed as a residuary double taxation relief provision covering foreign income that had already suffered tax abroad and was again included in the assessee&#039;s total income in India. The majority held that relief is not confined to an identical item matched by the same head or source in both jurisdictions, and that the statutory phrase &quot;such doubly taxed income&quot; does not require a narrow item-by-item correspondence. Hegde J. dissented, taking the view that only the same income actually taxed in both countries could qualify for relief.</description>
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    <pubDate>Wed, 11 Oct 1972 00:00:00 +0530</pubDate>
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      <title>1972 (10) TMI 6 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6381</link>
      <description>Section 49D of the Indian Income-tax Act, 1922 was construed as a residuary double taxation relief provision covering foreign income that had already suffered tax abroad and was again included in the assessee&#039;s total income in India. The majority held that relief is not confined to an identical item matched by the same head or source in both jurisdictions, and that the statutory phrase &quot;such doubly taxed income&quot; does not require a narrow item-by-item correspondence. Hegde J. dissented, taking the view that only the same income actually taxed in both countries could qualify for relief.</description>
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      <pubDate>Wed, 11 Oct 1972 00:00:00 +0530</pubDate>
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