https://www.taxtmi.com/caselaws?id=29486 Dividend received by a resident shareholder from foreign companies was taxable in India only on the net amount after the foreign tax deducted at source, because the deducted tax component was not income that accrued or arose to the assessee under the Income-tax Act, 1961. Reading sections 5, 8, 194, 198 and 199 together, the Court treated the statutory deduction as occurring before accrual to the shareholder. On that basis, the net dividend alone formed the doubly taxed income, and relief under section 91 was available on that net amount. en-us Thu, 12 Feb 1981 00:00:00 +0530 Sat, 13 Mar 2010 12:34:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=29486 Dividend received by a resident shareholder from foreign companies was taxable in India only on the net amount after the foreign tax deducted at source, because the deducted tax component was not income that accrued or arose to the assessee under the Income-tax Act, 1961. Reading sections 5, 8, 194, 198 and 199 together, the Court treated the statutory deduction as occurring before accrual to the shareholder. On that basis, the net dividend alone formed the doubly taxed income, and relief under section 91 was available on that net amount. Case-Laws Income Tax Thu, 12 Feb 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=29486