Elimination of Double Taxation

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....rectly or by deduction in respect of income from sources within Bangladesh which has been subjected to tax both in Bangladesh and India shall be allowed as a credit against Indian tax payable in respect of that income. The credit shall not, however, exceed that proportion of Indian tax which the income from sources within Bangladesh bears to the entire income subject to Indian tax : PROVIDED that such credit shall not exceed Indian tax (as computed before allowing any such credit), which is appropriate to the income derived from sources within Bangladesh, so however, that where such resident is a company by which surtax is payable in India the credit aforesaid shall be allowed in the first instance, against income-tax payable by the....

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....espects so as not to affect its general character: PROVIDED that the amount of the tax referred to in this paragraph shall not, however, exceed: (a) in the case of dividends an amount equal to 10 per cent of the gross amount of such dividends in the case of dividends referred to in paragraph 2(a) of Article 11 and 15 per cent of the gross amount of dividends in the case of dividends referred to in paragraph 2(b) of Article 11; (b) in the case of interest an amount equal to 10 per cent of the gross amount of such interest; and (c) in the case of royalties an amount equal to 10 per cent of the gross amount of such royalties. (3) In the case of a resident of Bangladesh, double taxation shall....