(1) Subject to the provisions of sub-section (2), a claim for approval as credit for foreign tax paid in respect of any income shall be 2 (two) years after the assessment year in which such income was or would have been chargeable in Bangladesh within the year the office in which the income tax of the said assessee has been imposed should be raised with the Commissioner of Taxes.

(2) For the purpose of claiming refund of tax or reassessment of tax in circumstances arising as a result of the adjustment, where the benefit provided under the agreement is deemed to be excessive or insufficient as a result of adjustment of any tax payable in Bangladesh or as a result of adjustment of any tax payable under the law of any other State, as provided in this Act the time
limit shall not apply if the assessment or refund claim is not satisfied within 2 (two) years after all such assessments, adjustments and other assessments arising therefrom have been completed in Bangladesh or elsewhere.