Under what circumstances can Unilateral Relief be granted to avoid Double Taxation under section 91 of Income Tax Act 1961?

Under the following circumstances, the Indian Government can grant Unilateral Relief from double taxation u/s 91 of the Income Tax Act, 1961, if: The person or company has been resident of India in the previous year. The Income must have accrued to and received by the tax payer outside India in the previous year. The Income should have been taxed in India and in another country with which there is no tax treaty. The person or company had paid tax under the laws of the foreign country in question. On a similar note, the unilateral relief can be granted to any person who is resident in India in any previous year proves that in respect of his income which accrued or arose to him during that previous year in Pakistan he has paid in that country, by deduction or otherwise, tax payable to the Government under any law for the time being in force in that country relating to taxation of agricultural income. Similarly, unilateral relief can be granted to any non-resident person is assessed on his share in the income of a registered firm assessed as resident in India in any previous year and such share includes any income accruing or arising outside India during that previous year (and which is not deemed to accrue or arise in India) in a country with which there is no agreement under section 90 for the relief or avoidance of double taxation and he proves that he has paid income-tax by deduction or otherwise under the law in force in that country in respect of the income so included.