https://www.taxtmi.com/caselaws?id=28899 Indian assessment could include computation of income attributable to Pakistan for rebate purposes, with the Income-tax Officer treated as competent to make that calculation for restricting relief on doubly taxed income. Article VI(b) of the India-Pakistan double taxation agreement was construed as a machinery provision: the demand to be kept in abeyance was the portion equal to the estimated foreign-tax abatement, and any excess collected after giving effect to advance tax payment was refundable. Interest was stated to run on the refundable amount under section 214 until actual refund where the refund was delayed. en-us Mon, 21 Sep 1981 00:00:00 +0530 Mon, 08 Mar 2010 15:05:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28899 Indian assessment could include computation of income attributable to Pakistan for rebate purposes, with the Income-tax Officer treated as competent to make that calculation for restricting relief on doubly taxed income. Article VI(b) of the India-Pakistan double taxation agreement was construed as a machinery provision: the demand to be kept in abeyance was the portion equal to the estimated foreign-tax abatement, and any excess collected after giving effect to advance tax payment was refundable. Interest was stated to run on the refundable amount under section 214 until actual refund where the refund was delayed. Case-Laws Income Tax Mon, 21 Sep 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28899