https://www.taxtmi.com/caselaws?id=276685 Under the double-taxation agreement, Pakistan-related dividend income remained includible in the resident assessee's total income because relief was granted by abatement rather than exclusion at the assessment stage. Grossing up and corresponding tax credit applied only to the portion of the dividend representing income taxable in the taxable territories, not to the entire dividend. Abatement for the Pakistan-related dividend was available only where the tax payable in Pakistan was shown by a certificate of assessment or other admissible proof when it was not otherwise known. The reference was answered substantially in favour of the Revenue, subject to the existing abatement benefit on the facts. en-us Tue, 17 Sep 1957 00:00:00 +0530 Thu, 15 Nov 2018 18:24:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276685 Under the double-taxation agreement, Pakistan-related dividend income remained includible in the resident assessee's total income because relief was granted by abatement rather than exclusion at the assessment stage. Grossing up and corresponding tax credit applied only to the portion of the dividend representing income taxable in the taxable territories, not to the entire dividend. Abatement for the Pakistan-related dividend was available only where the tax payable in Pakistan was shown by a certificate of assessment or other admissible proof when it was not otherwise known. The reference was answered substantially in favour of the Revenue, subject to the existing abatement benefit on the facts. Case-Laws Income Tax Tue, 17 Sep 1957 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276685