https://www.taxtmi.com/caselaws?id=8510 Article III of the India-Ceylon double taxation agreement was construed to require relief by reference to the actual tax amounts attributable to the excess income in each country, not by comparing the respective tax rates. On that interpretation, abatement is determined by the lower of the two tax amounts, and the relief is granted only to that extent. The Madras High Court followed the earlier view that the agreement focuses on tax attributable to the excess income rather than prevailing rate levels, and upheld the Tribunal's computation of double tax relief for the assessee. en-us Wed, 01 Mar 1972 00:00:00 +0530 Mon, 27 Apr 2009 17:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8510 Article III of the India-Ceylon double taxation agreement was construed to require relief by reference to the actual tax amounts attributable to the excess income in each country, not by comparing the respective tax rates. On that interpretation, abatement is determined by the lower of the two tax amounts, and the relief is granted only to that extent. The Madras High Court followed the earlier view that the agreement focuses on tax attributable to the excess income rather than prevailing rate levels, and upheld the Tribunal's computation of double tax relief for the assessee. Case-Laws Income Tax Wed, 01 Mar 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8510