1980 (2) TMI 136

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..... the asst. yr. 1978-79, the ITO added a sum of Rs. 4,190 observing as follows: "Foreign income included subject to relief under DITR settlement- Rs. 4,190". The assessee went up in appeal before the AAC and contended before him that the income of the assessee arising out of immovable property in Malaysia was exempt. The AAC observed that the assessee should furnish certificate to the effect tha .....

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..... s case since the implication of the articles 6, 7 and 22 of the Agreement for the avoidance of double taxation of income and the prevention of fiscal evasion of tax between the Govt. of India and the Govt. of Malaysia was not considered therein. 4. I have considered the rival submissions. It is common ground that the income under dispute arose out of the immovable properties situate in Malaysia. .....

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