https://www.taxtmi.com/caselaws?id=189722 Relief for double income-tax under section 49D is confined to the income that has actually borne tax in both jurisdictions. An amount computed for assessment purposes does not qualify as doubly taxed income if part of it was excluded by allowance or set-off before charge. The proper inquiry is the quantum that in fact suffered tax under both Malaya and India, not the entire amount attributed to the source. On that basis, only the smaller sum constituted doubly taxed income, and relief was available only to that extent. en-us Wed, 19 Apr 1961 00:00:00 +0530 Wed, 18 Jan 2017 16:52:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189722 Relief for double income-tax under section 49D is confined to the income that has actually borne tax in both jurisdictions. An amount computed for assessment purposes does not qualify as doubly taxed income if part of it was excluded by allowance or set-off before charge. The proper inquiry is the quantum that in fact suffered tax under both Malaya and India, not the entire amount attributed to the source. On that basis, only the smaller sum constituted doubly taxed income, and relief was available only to that extent. Case-Laws Income Tax Wed, 19 Apr 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189722