https://www.taxtmi.com/caselaws?id=7601 Double tax relief under the India-Ceylon agreement had to be computed by reference to the actual amounts of tax attributable to the excess in each country, because Article III used the phrase "amounts of tax" and not tax rates. Relief could not be recalculated by comparing only the prevailing rates in the two countries, so the original allowance of double tax relief was upheld. The challenge to proceedings under section 147 was not examined on merits because the reference on that question was incompetent for want of the prescribed application. en-us Fri, 18 Apr 1969 00:00:00 +0530 Thu, 05 Mar 2009 13:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7601 Double tax relief under the India-Ceylon agreement had to be computed by reference to the actual amounts of tax attributable to the excess in each country, because Article III used the phrase "amounts of tax" and not tax rates. Relief could not be recalculated by comparing only the prevailing rates in the two countries, so the original allowance of double tax relief was upheld. The challenge to proceedings under section 147 was not examined on merits because the reference on that question was incompetent for want of the prescribed application. Case-Laws Income Tax Fri, 18 Apr 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7601