https://www.taxtmi.com/caselaws?id=6887 Under Article III of the India-Ceylon double taxation agreement, abatement was confined to the tax actually payable after statutory deductions and reliefs, not the gross tax initially assessed in Ceylon. The clause required each State to assess income under its own laws and granted relief only to the extent the same income was charged in both countries beyond the treaty percentage. The phrase "tax attributable to such excess" was therefore construed as referring to net tax after deductions, because a broader reading would extend relief beyond the treaty's purpose of preventing double taxation on identical income. The claim for abatement on gross tax was rejected. en-us Thu, 19 Jan 1967 00:00:00 +0530 Fri, 06 Feb 2009 18:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6887 Under Article III of the India-Ceylon double taxation agreement, abatement was confined to the tax actually payable after statutory deductions and reliefs, not the gross tax initially assessed in Ceylon. The clause required each State to assess income under its own laws and granted relief only to the extent the same income was charged in both countries beyond the treaty percentage. The phrase "tax attributable to such excess" was therefore construed as referring to net tax after deductions, because a broader reading would extend relief beyond the treaty's purpose of preventing double taxation on identical income. The claim for abatement on gross tax was rejected. Case-Laws Income Tax Thu, 19 Jan 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6887