PADMAVATI R. SARAIYA AND OTHERS vs COMMISSIONER OF INCOME-TAX BOMBAY CITY-1

The Supreme Court ruled that under the Income-tax Act, 1922, specifically Section 49AA and the Indo-Pakistan Agreement of 1947, the assessee was not entitled to relief as no certificate of assessment from Pakistan was produced, thus affirming the High Court's decision on this point. Additionally, the Court held that the Pakistan portion of the dividend was not credited to the assessee's account, making it non-includable in total income under Section 16(2). Consequently, both appeals were dismissed.