https://www.taxtmi.com/caselaws?id=7184 Under the double taxation agreement, abatement under article IV had to be computed on the Pakistan income as assessed in India, because the same income figure must be used consistently for the domestic assessment, the excess calculation, and the tax comparison; the lower Pakistan assessment could not replace it. For article V, the full foreign income had to be taken into account for comparison in each Dominion, and only then could one-half of the lower tax be allowed as relief; using only half the Pakistan figure was inconsistent with the agreement. The recalculation was required on these principles, and the assessee succeeded while the Revenue failed. en-us Tue, 05 Dec 1967 00:00:00 +0530 Thu, 12 Feb 2009 12:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7184 Under the double taxation agreement, abatement under article IV had to be computed on the Pakistan income as assessed in India, because the same income figure must be used consistently for the domestic assessment, the excess calculation, and the tax comparison; the lower Pakistan assessment could not replace it. For article V, the full foreign income had to be taken into account for comparison in each Dominion, and only then could one-half of the lower tax be allowed as relief; using only half the Pakistan figure was inconsistent with the agreement. The recalculation was required on these principles, and the assessee succeeded while the Revenue failed. Case-Laws Income Tax Tue, 05 Dec 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7184