Protocol

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..... the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed upon the following additional provisions which shall form an integral part of the said Convention. It is understood :- (a) that, with reference to Article 7, paragraph 3, the expression "expenses which are incurred for the purposes of .....

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..... ing (PP.TT.), to the Italian Foreign Trade Institution (I.C.E.), to the Italian Tourism body (E.N.I.T.), and to any corresponding Indian body or institution, are covered by the provisions concerning Government service and, consequently, by paragraphs 1 and 2 of the aforesaid Article. Other public bodies or institutions may also be included in the preceding list by mutual agreement between the co .....

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..... h is agreed by the competent authorities of the Contracting States to be of a substantially similar character, if it has been modified only in minor respects so as not to affect its general character; (e) that, with reference to Article 26, paragraph 1, the expression "notwithstanding the remedies provided by the national laws" means that the mutual agreement procedure is not alternati .....

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