Relief from double taxation

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....t against the United States tax on income- (a) the income-tax paid to India by or on behalf of such citizen or resident; and (b) in the case of a United States company owning at least 10 per cent of the voting stock of a company which is a resident of India and from which the United States company receives dividends, the income-tax paid to India by or on behalf of the distributin....

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....tax is payable in India, the deduction in respect of income-tax paid in the United States shall be allowed in the first instance from income-tax payable by the company in India and as to the balance, if any, from surtax payable by it in India. 3. For the purposes of allowing relief from double taxation pursuant to this article, income shall be deemed to arise as follows: (a) income der....