https://www.taxtmi.com/caselaws?id=7179 Article III of the India-Ceylon double taxation relief agreement, read with the relevant Schedule and section 49A of the Indian Income-tax Act, 1922, limited abatement to the lower tax attributable to the same excess income in both countries. As the Schedule prescribed a nil percentage for the income in question, the entire assessed amount constituted the excess. The attributable taxes on that excess were Rs. 704 in Ceylon and Rs. 1,876.50 in India, so the agreement required relief only up to the lower figure. The assessee was therefore not entitled to any abatement beyond Rs. 704. en-us Wed, 15 Jun 1966 00:00:00 +0530 Thu, 12 Feb 2009 12:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7179 Article III of the India-Ceylon double taxation relief agreement, read with the relevant Schedule and section 49A of the Indian Income-tax Act, 1922, limited abatement to the lower tax attributable to the same excess income in both countries. As the Schedule prescribed a nil percentage for the income in question, the entire assessed amount constituted the excess. The attributable taxes on that excess were Rs. 704 in Ceylon and Rs. 1,876.50 in India, so the agreement required relief only up to the lower figure. The assessee was therefore not entitled to any abatement beyond Rs. 704. Case-Laws Income Tax Wed, 15 Jun 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7179