Agreement between Government of India and Imperial Government of Iran through exchange of notes for avoidance of double taxation of income of enterprises operating aircraft

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..... operating aircraft Dated 28/5/1973 G.S.R. 284(E)-Whereas the Government of India and the Imperial Government of Iran have concluded an agreement through exchange of notes as set out in the Annexure hereto, for the avoidance of double taxation of income of enterprises operating aircraft; Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), .....

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..... t of income-tax on a reciprocal basis; and in fact considering that no income-tax has been collected from Iranian air companies in India, the Iranian Government has to this date refrained from collecting income-tax from Indian air companies. Thus, as the provisions of reciprocity prescribed in the Direct Tax Law, has been in fact established, as long as the said provision is observed by the India .....

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..... airlines from payment of income-tax, has the honour to refer to their Note No. 127/18, dated March 29, 1973, which reads as follows:- "The Imperial Ministry of Foreign Affairs presents its compliments to the Embassy of India and with reference to the discussions and corresponding notes exchanged regarding the reciprocal exemption of Indian and Iranian airlines from payment of income-tax has .....

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..... servance of reciprocity by the Government of India may be considered as a temporary agreement between the two parties in respect of exemption from payment of income-tax by the air companies of both parties." With reference to this proposal, the Embassy of India has the honour to inform the Imperial Ministry of Foreign Affairs that the Government of India accepts the terms of the foregoing te .....

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