https://www.taxtmi.com/caselaws?id=40056 A double taxation relief agreement does not, by itself, exclude Pakistan-source dividend income from assessability under the Indian Income-tax Act, 1922. The agreement operated only to grant relief by abatement after assessment, while domestic law continued to govern whether the income formed part of total income. Income chargeable under the Act and not exempt under its provisions had to be included in computing total income, and could then be considered for set-off under section 24(1). The foreign dividend was therefore brought within the Indian assessment framework for loss computation and statutory set-off. en-us Tue, 15 Jul 1986 00:00:00 +0530 Wed, 29 Oct 2025 18:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=40056 A double taxation relief agreement does not, by itself, exclude Pakistan-source dividend income from assessability under the Indian Income-tax Act, 1922. The agreement operated only to grant relief by abatement after assessment, while domestic law continued to govern whether the income formed part of total income. Income chargeable under the Act and not exempt under its provisions had to be included in computing total income, and could then be considered for set-off under section 24(1). The foreign dividend was therefore brought within the Indian assessment framework for loss computation and statutory set-off. Case-Laws Income Tax Tue, 15 Jul 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=40056