https://www.taxtmi.com/caselaws?id=35932 Only the net foreign dividend actually received by a resident assessee was includible in total income under section 5(1)(c) of the Income-tax Act, 1961, because that provision covers income that actually accrues or arises outside India. The court distinguished actual accrual from deeming fictions and noted that, although the Act contains a specific deeming rule for certain dividend receipts from Indian companies, it contains no equivalent rule treating foreign tax deducted abroad as income of the shareholder. Amounts deducted as foreign tax never accrued to the assessee and could not be taxed as part of the gross dividend. en-us Thu, 24 Jul 1980 00:00:00 +0530 Thu, 18 Mar 2010 10:44:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35932 Only the net foreign dividend actually received by a resident assessee was includible in total income under section 5(1)(c) of the Income-tax Act, 1961, because that provision covers income that actually accrues or arises outside India. The court distinguished actual accrual from deeming fictions and noted that, although the Act contains a specific deeming rule for certain dividend receipts from Indian companies, it contains no equivalent rule treating foreign tax deducted abroad as income of the shareholder. Amounts deducted as foreign tax never accrued to the assessee and could not be taxed as part of the gross dividend. Case-Laws Income Tax Thu, 24 Jul 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35932