https://www.taxtmi.com/caselaws?id=9292 Section 49A, as amended, distinguishes statutory relief for double taxation from treaty-based avoidance of double taxation. Abatement under an agreement for avoidance of double taxation with Pakistan was treated as a separate mechanism, not a relief due under the other provisions of the Indian Income-tax Act, 1922 for purposes of Explanation (ii) to section 49D(3). The Indian rate of tax therefore had to be computed without deducting that abatement, and the construction of the charging and relief provisions was applied strictly in favour of the taxpayer. en-us Wed, 30 May 1973 00:00:00 +0530 Sun, 21 Jun 2009 17:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9292 Section 49A, as amended, distinguishes statutory relief for double taxation from treaty-based avoidance of double taxation. Abatement under an agreement for avoidance of double taxation with Pakistan was treated as a separate mechanism, not a relief due under the other provisions of the Indian Income-tax Act, 1922 for purposes of Explanation (ii) to section 49D(3). The Indian rate of tax therefore had to be computed without deducting that abatement, and the construction of the charging and relief provisions was applied strictly in favour of the taxpayer. Case-Laws Income Tax Wed, 30 May 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9292