Held that the assessee did not pay any tax in India in respect of sales of units eligible for deduction under S. 10AA made to Australia and Canada, benefit of tax paid in Australia and Canada cannot be allowed against Indian income-tax liability of the assessee under art. 24 of the DTAA between India and Australia and art. 23 of DTAA between India and Canada. Since the income from S. 10AA units arising in Belgium is chargeable to tax in India, even though it is not subjected to tax because of the deduction provided by this section, the requirement of chargeable under the Act stands fulfilled in terms of S. 90(1)(a)(i) r/w art. 23 of DTAA and, therefore, relief is allowable in respect of tax paid on such income in Belgium; language of para 2(a) of art. 23 of the DTAA between India and Japan, para 1(a) of art. 23 of the DTAA between India and Switzerland and para 2 of art. 24 of the DTAA between India and Malaysia is similar to that of the DTAA between India and Belgium and, therefore, taxes paid by the assessee in Japan, Switzerland and Malaysia are eligible for credit. (AY. 2013-14)