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    <title>1971 (5) TMI 20 - CALCUTTA High Court</title>
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    <description>Tax deducted from United Kingdom dividends was not a pure question of fact, because it required construction of the foreign taxing statute and relevant judicial authorities; the reference was therefore competent and the preliminary objection failed. On the merits, section 49D of the Indian Income-tax Act, 1922 allowed relief where foreign income had suffered tax by deduction or otherwise under the foreign law. Tax deducted at source from dividends paid out of taxed profits in the United Kingdom was treated as income-tax suffered by the shareholder, and relief was available because the foreign tax rate could be ascertained. The reference was answered in favour of the assessee.</description>
    <language>en-us</language>
    <pubDate>Tue, 11 May 1971 00:00:00 +0530</pubDate>
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      <title>1971 (5) TMI 20 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=8422</link>
      <description>Tax deducted from United Kingdom dividends was not a pure question of fact, because it required construction of the foreign taxing statute and relevant judicial authorities; the reference was therefore competent and the preliminary objection failed. On the merits, section 49D of the Indian Income-tax Act, 1922 allowed relief where foreign income had suffered tax by deduction or otherwise under the foreign law. Tax deducted at source from dividends paid out of taxed profits in the United Kingdom was treated as income-tax suffered by the shareholder, and relief was available because the foreign tax rate could be ascertained. The reference was answered in favour of the assessee.</description>
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      <pubDate>Tue, 11 May 1971 00:00:00 +0530</pubDate>
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