https://www.taxtmi.com/caselaws?id=191187 Relief under a double taxation agreement had to be claimed within the assessment process, not after final assessment and payment. The assessee's application was treated as one for abatement, but it was made too late because the assessments had been completed, the tax paid, and no outstanding demand remained for adjustment; if treated as a refund claim under section 48, it was also barred by limitation. The rejection of that late claim did not itself give rise to a further appeal, since the proper challenge was against the original assessment orders while they remained open. en-us Mon, 27 Aug 1962 00:00:00 +0530 Thu, 23 Mar 2017 18:14:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=191187 Relief under a double taxation agreement had to be claimed within the assessment process, not after final assessment and payment. The assessee's application was treated as one for abatement, but it was made too late because the assessments had been completed, the tax paid, and no outstanding demand remained for adjustment; if treated as a refund claim under section 48, it was also barred by limitation. The rejection of that late claim did not itself give rise to a further appeal, since the proper challenge was against the original assessment orders while they remained open. Case-Laws Income Tax Mon, 27 Aug 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=191187