https://www.taxtmi.com/caselaws?id=49354 Under section 49AA of the Indian Income-tax Act, 1922 and the Indo-Pakistan Agreement, assessment could be made in the ordinary way under domestic law, with relief operating only through the Agreement's abatement mechanism. The Pakistan portion of dividend income was treated as part of the assessee's total income under section 2(15). Dividend was regarded as credited or paid under section 16(2) only when it was unconditionally made available to the shareholder; the postponed moiety, not credited to a separate account and not shown to be so available, did not satisfy that test. en-us Tue, 22 Sep 1964 00:00:00 +0530 Fri, 22 Aug 2014 11:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49354 Under section 49AA of the Indian Income-tax Act, 1922 and the Indo-Pakistan Agreement, assessment could be made in the ordinary way under domestic law, with relief operating only through the Agreement's abatement mechanism. The Pakistan portion of dividend income was treated as part of the assessee's total income under section 2(15). Dividend was regarded as credited or paid under section 16(2) only when it was unconditionally made available to the shareholder; the postponed moiety, not credited to a separate account and not shown to be so available, did not satisfy that test. Case-Laws Income Tax Tue, 22 Sep 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49354