Elimination of double taxation

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....er than Korea (which shall not affect the general principle hereof), the Indian tax payable (excluding in the case of a dividend, tax payable in respect of the profit out of  which the dividend is paid) under the laws of India and in accordance with this convention, whether directly or by deduction, in respect of income from sources within India shall be allowed as a credit against Korean tax....

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....ates, provided that the amount of the tax referred to in this paragraph shall not, however, exceed: (a) in the case of dividends referred to in paragraph 2 (a) of Article 11, an amount of 15 per cent, of the gross amount of such dividends and, in the case of dividends referred to in paragraph 2(b) of Article 11, an amount of 20 per cent. of the gross amount of such dividends; (b) i....

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....ts out of which the dividend is paid) under the laws of Korea and in accordance with this Convention, whether directly or by deduction, in respect of income from sources within Korea 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 Korea bears to the entire inc....

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....ce 11, an amount of 15 per cent. of the gross amount of such dividends and, in the case of the dividends referred to in paragraph 2(b) of Article 11, an amount of 20 per cent. of the gross amount of such dividends; (b) in the case of interest referred to in paragraph 2 of Article 12, an amount of 15 per cent. of the gross amount of such interest and in the case of interest referred to in p....