164. Unilateral relief:-

If any person who is resident in Pakistan in any year proves to the satisfaction of the Deputy Commissioner that, in respect of any income which has accrued or arisen to him during that year outside Pakistan, he has paid income tax, by deduction or otherwise, in any country (including a country with which there is an agreement under section 163 for the avoidance of double taxation, the Deputy Commissioner may, subject to such rules as may be made in this behalf, deduct from the tax payable by him under this Ordinance a sum equal to the tax calculated on such doubly-taxed income at the average rate of tax of Pakistan or the average rate of tax of the said country, whichever is the lower.