Elimination of Double Taxation

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.... the case of India as follows : (a) Where a resident of India derives income which, in accordance with the provisions of this Convention, may be taxed in Japan, India shall allow as a deduction from the tax on the income of that resident an amount equal to the Japanese tax paid in Japan, whether directly or by deduction. Such deduction in either case shall not, however, exceed that p....

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.... 3. Subject to the laws of Japan regarding the allowance as a credit against Japanese tax of tax payable in any country other than Japan : (a) Where a resident of Japan derives income from India which may be taxed in India in accordance with the provisions of this Convention, the amount of Indian tax payable in respect of that income shall be allowed as a credit against the Japanese ....

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.... of the credit referred to in sub-paragraphs (a) and (b) above, there shall be deemed to have been paid by the tax payer the amount which would have been paid as Indian tax under the laws of India and in accordance with this Convention if the Indian tax had not been reduced or relieved in accordance with the special incentive measures designed to promote economic development in India, effective on....