C.I.T., WEST BENGAL III, CALCUTTA vs CAREW & CO. LTD.

The Supreme Court held that under the Indian Income Tax Act, 1922, the assessee is entitled to relief against double taxation as per the Agreement for Avoidance of Double Taxation, specifically allowing the set-off of losses from agricultural properties in Pakistan against profits from manufacturing business. The Court clarified that agricultural income or loss from foreign properties must be included in the total income calculation, thus affirming the Tribunal's decision. The appeal was dismissed, upholding the High Court's agreement with the Tribunal's view.