K. V. A. L. M. RAMANATHAN CHETTIAR BY L.RS. vs COMMISSIONER OF INCOME-TAX, MADRAS

The Supreme Court held that Section 49-D of the Income Tax Act provides relief for 'such doubly taxed income' by allowing a deduction of the lower of Indian income tax paid or tax paid in a foreign country. The Court clarified that the phrase 'such doubly taxed income' refers to foreign income included in total income under Section 3 and Section 2(15) of the Act, which is subject to Indian tax. The High Court's interpretation was deemed erroneous, and the Court ruled in favor of the assessee, allowing the deduction as per the amended provisions of Section 49-D.