Report No. 12
25. Amounts not deductible.-
Notwithstanding anything contained in section 24 [section regarding deductions], the following amounts shall not be deducted in computing the income chargeable under the head "Income from house property"-
any annual charge or interest chargeable under this Act which is payable outside India (not being interest on a loan issued for public subscription before the 1st day of April, 1938), on which tax has not been paid or deducted under section 202 or 204  and in respect of which there is no person in India who may be treated as an agent under section 173 .
[Section 9(1)(iv), proviso]