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    <title>1980 (4) TMI 63 - BOMBAY High Court</title>
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    <description>For abatement of tax under article IV of the India-Pakistan Double Taxation Avoidance Agreement, the controlling figure was the income assessed by the taxing Dominion under its own domestic law, not the amount assessed by the other Dominion. The agreement preserved separate ordinary assessments under each law and used the Schedule only to compute the excess on which abatement was granted, so Pakistani factory income remained part of the Indian assessment for that purpose. The Indian Income-tax Officer was also competent to determine income from Pakistan sources for Indian assessment, because the agreement did not curtail domestic assessment power but only regulated retention and abatement of tax. The reference was answered against the assessee.</description>
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    <pubDate>Thu, 17 Apr 1980 00:00:00 +0530</pubDate>
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      <title>1980 (4) TMI 63 - BOMBAY High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=36465</link>
      <description>For abatement of tax under article IV of the India-Pakistan Double Taxation Avoidance Agreement, the controlling figure was the income assessed by the taxing Dominion under its own domestic law, not the amount assessed by the other Dominion. The agreement preserved separate ordinary assessments under each law and used the Schedule only to compute the excess on which abatement was granted, so Pakistani factory income remained part of the Indian assessment for that purpose. The Indian Income-tax Officer was also competent to determine income from Pakistan sources for Indian assessment, because the agreement did not curtail domestic assessment power but only regulated retention and abatement of tax. The reference was answered against the assessee.</description>
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      <pubDate>Thu, 17 Apr 1980 00:00:00 +0530</pubDate>
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