https://www.taxtmi.com/caselaws?id=20133 HC held that income from rubber estates in Malaysia cannot be included in the assessee's total income or assessed to tax in India under the Income-tax Act, 1961. Applying the India-Malaysia DTAA, business profits attributable to the Malaysian source are taxable only in Malaysia where the permanent establishment exists; Indian authorities cannot assess them. Where double taxation arises, tax credit/relief under the agreement applies. The Tribunal's finding that no separate establishment was maintained in India for the Malaysian estates was upheld as relevant and supported by materials. en-us Tue, 15 Mar 1994 00:00:00 +0530 Thu, 16 Oct 2025 21:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=20133 HC held that income from rubber estates in Malaysia cannot be included in the assessee's total income or assessed to tax in India under the Income-tax Act, 1961. Applying the India-Malaysia DTAA, business profits attributable to the Malaysian source are taxable only in Malaysia where the permanent establishment exists; Indian authorities cannot assess them. Where double taxation arises, tax credit/relief under the agreement applies. The Tribunal's finding that no separate establishment was maintained in India for the Malaysian estates was upheld as relevant and supported by materials. Case-Laws Income Tax Tue, 15 Mar 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=20133