https://www.taxtmi.com/caselaws?id=38245 Rule 2(b) of the Income-tax (Double Taxation Relief) (United Kingdom) Rules, 1948 separates Indian income-tax and Indian super-tax for computing the Indian rate of tax. Where the rule expressly requires exclusion of exempt income for the income-tax component but contains no similar adjustment for super-tax, the formula must be applied as written. The gross Indian super-tax is therefore divided by the gross total income, without reducing the denominator by Pakistan income for that component. The stated effect is that double taxation relief is computed on the plain language of the rule, with no implied deduction added to the super-tax calculation. en-us Fri, 17 Jun 1977 00:00:00 +0530 Mon, 05 Apr 2010 11:34:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38245 Rule 2(b) of the Income-tax (Double Taxation Relief) (United Kingdom) Rules, 1948 separates Indian income-tax and Indian super-tax for computing the Indian rate of tax. Where the rule expressly requires exclusion of exempt income for the income-tax component but contains no similar adjustment for super-tax, the formula must be applied as written. The gross Indian super-tax is therefore divided by the gross total income, without reducing the denominator by Pakistan income for that component. The stated effect is that double taxation relief is computed on the plain language of the rule, with no implied deduction added to the super-tax calculation. Case-Laws Income Tax Fri, 17 Jun 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38245