Elimination of double taxation

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....law of India and consistently with Convention, whether directly or by deduction, in respect of income derived by a resident of New Zealand from sources in India (excluding, in the case of a dividend, tax paid in respect of the profits out of which the dividend is paid), shall be allowed as a credit against New Zealand tax payable in respect of that income. (b) For the purposes of this Article, ....

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....this article, income of a resident of India which in accordance with the provisions of this Convention may be taxed in New Zealand shall be deemed to arise from sources in New Zealand. 3. For the purposes of paragraph (1) the term Indian tax paid shall be deemed to include any amount which would have been payable as Indian tax but for a deduction allowed in computing the taxable income or an ex....