https://www.taxtmi.com/caselaws?id=7387 Relief from double taxation under section 49D depends on identity of the income taxed in both jurisdictions: only income that has actually suffered tax under Indian law and a foreign tax system can be treated as doubly taxed. Indian income from other sources, which had not itself borne foreign tax, could not be included in the relief computation merely because it formed part of total world income for Indian tax purposes. The allowance is confined to factual double taxation of the same income, not a notional set-off or composite aggregation. On that basis, relief for the assessee was not available on the Indian income from other sources. en-us Tue, 12 Mar 1968 00:00:00 +0530 Thu, 19 Feb 2009 10:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7387 Relief from double taxation under section 49D depends on identity of the income taxed in both jurisdictions: only income that has actually suffered tax under Indian law and a foreign tax system can be treated as doubly taxed. Indian income from other sources, which had not itself borne foreign tax, could not be included in the relief computation merely because it formed part of total world income for Indian tax purposes. The allowance is confined to factual double taxation of the same income, not a notional set-off or composite aggregation. On that basis, relief for the assessee was not available on the Indian income from other sources. Case-Laws Income Tax Tue, 12 Mar 1968 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7387