https://www.taxtmi.com/caselaws?id=19888 For a resident assessee, only income actually accruing or arising outside India is taxable under section 5(1)(c) of the Income-tax Act, 1961, unless the Act contains an express deeming provision to gross up the foreign receipt. The deeming rules applied to dividend income received in India under sections 194 and 198 do not extend to tax deducted by a foreign payer under foreign law. In the absence of any comparable statutory provision for foreign dividends and interest on securities, the amount withheld in the United Kingdom could not be treated as part of the assessee's chargeable income, and the foreign tax deducted at source was excluded. en-us Tue, 12 Apr 1994 00:00:00 +0530 Wed, 31 May 2017 14:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19888 For a resident assessee, only income actually accruing or arising outside India is taxable under section 5(1)(c) of the Income-tax Act, 1961, unless the Act contains an express deeming provision to gross up the foreign receipt. The deeming rules applied to dividend income received in India under sections 194 and 198 do not extend to tax deducted by a foreign payer under foreign law. In the absence of any comparable statutory provision for foreign dividends and interest on securities, the amount withheld in the United Kingdom could not be treated as part of the assessee's chargeable income, and the foreign tax deducted at source was excluded. Case-Laws Income Tax Tue, 12 Apr 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19888