https://www.taxtmi.com/caselaws?id=8585 Relief under the India-Pakistan double taxation arrangement was confined to income categories actually covered by the agreement and had to be computed source-wise for taxable Pakistan business income. Agricultural income in Pakistan was outside the agreement because it was not taxable under the relevant income-tax law, so the related agricultural loss could not be set off to reduce the abatable manufacturing business income. The later statutory relief for foreign agricultural income under section 49D(3) reinforced the separation between covered business income and income outside the treaty scope. The assessee was therefore entitled to abatement on the full Pakistan manufacturing business income without adjustment for the agricultural loss. en-us Thu, 08 Jul 1971 00:00:00 +0530 Tue, 05 May 2009 16:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8585 Relief under the India-Pakistan double taxation arrangement was confined to income categories actually covered by the agreement and had to be computed source-wise for taxable Pakistan business income. Agricultural income in Pakistan was outside the agreement because it was not taxable under the relevant income-tax law, so the related agricultural loss could not be set off to reduce the abatable manufacturing business income. The later statutory relief for foreign agricultural income under section 49D(3) reinforced the separation between covered business income and income outside the treaty scope. The assessee was therefore entitled to abatement on the full Pakistan manufacturing business income without adjustment for the agricultural loss. Case-Laws Income Tax Thu, 08 Jul 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8585