Indian Nationals having income arising in Pakistan--Collection of tax--Clarification regarding

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....All Commissioners of Income-tax. Sir, Subject :  Indian Nationals having income arising in Pakistan--Collection of tax--Clarification regarding. Reference is invited to Board's Circular No. 25 issued under its F.No. 9/20/68-ITA-II dated 25th July, 1969.* Para. 2(a) of the said circular relating to sub-section (7) of section 220 reads as under: "The Income-tax Officers ask the asse....

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....-tax Officer under section 220(7)." 2. In the case of A.C. Paul v. TRO [Writ Petition No. 359 of 1975] ([1979] 117 ITR 412 (Mad), the Madras High Court had occasion to interpret sub-section (7) of section 220 of the Income-tax Act, 1961, as also to examine the scope and the correctness of the portion of the Board's Circular extracted in the preceding paragraph. The observations of the High Cour....

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..... We have already extracted the relevant and the emphatic part of that circular and we should repeat the words of that part. It is stated there that the tax on the Indian income must be determined by treating Indian income as the total income of the assessee and only that amount of tax should be recovered from the assessee. We are constrained to say that this direction by the CBDT is a direction d....