Countries with which no agreement exists.

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....ndia), he has paid in any country with which there is no agreement under section 159 for the relief or avoidance of double taxation, income-tax, by deduction or otherwise, under the law in force in that country, he shall be entitled to the deduction from the Indian income-tax payable by him of a sum calculated on such doubly taxed income,-- (a) at the Indian rate of tax or the rate of tax....

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.... (a) at the Indian rate of tax or the rate of tax of the said country, whichever is the lower; or (b) at the Indian rate of tax, if both the rates are equal. (3) In this section,- (a) "income-tax" in relation to any country includes any excess profits tax or business profits tax charged on the profits by the Government of any part of that country or a local authority in ....