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Protocol

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..... the procedures required by laws of the Contracting States for bringing into force of the said amending Protocol; Now, therefore, in exercise of the powers conferred by section 90 of the Income tax Act, 1961 (43 of 1961) , the Central Government hereby notifies that all the provisions of said amending protocol shall have effect in the Union of India with effect from the 6th day of August, 2017. ANNEXURE PROTOCOL AMENDING THE CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE GOVERNMENT OF THE FEDERATIVE REPUBLIC OF BRAZIL FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME, SIGNED AT NEW DELHI ON 26 APRIL, 1988 PREAMBLE The Government of the Republic of India and the Gover .....

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..... se the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. Notwithstanding the foregoing, information received by a Contracting State may be used for other purposes when such information may be used for such purposes under the laws of both States and the competent authority of the supplying State expressly authorizes such use in writing. 3. In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a Contracting State the obligation: A. to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; B. to supply information which is not obtainable under the laws or in the no .....

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..... its provisions shall have effect on that date. Article III This Protocol, which shall form an integral part of the Convention, shall remain in force as long as the Convention remains in force and shall apply as long as the Convention itself is applicable. IN WITNESS WHEREOF the undersigned, duly authorized, have signed this Protocol. DONE in duplicate at Brasilia, this 15 day of October, 2013, in the Hindi, Portuguese and English languages, all three texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. FOR THE GOVERNMENT OF THE REPUBLIC OF INDIA Sd/- Ashok Tomar Ambassador of India to Brazil FOR THE GOVERNMENT OF THE FEDERATIVE REPUBLIC OF BRAZIL Sd/- Carlos Barreto Secretary of the Federal .....

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..... derstood that the provisions of paragraph 5 of Article 10 are not in conflict with the provisions of paragraph 2 of Article 24. 5. It is understood that either Contracting State may, at any time not earlier than ten years from the date on which the Convention enters into force, seek to review any or all of its provisions, by notice in writing through competent authority thereof to the competent authority of the other Contracting State. The competent authorities shall, within a period of six months thereafter, initiate appropriate proceedings for such review. In witness whereof the undersigned being duly authorised thereto have signed this Protocol. Done at New Delhi this 26th day of April, 1988, in duplicate, in Hindi, Portuguese and Englis .....

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