Limitation of Benefits

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..... n purposes of any person concerned with the creation or assignment of such items of income to take advantage of the provisions of this Agreement. 2. In making a determination under paragraph 1, the appropriate competent authority or authorities shall be entitled to consider, among other factors, the amount and nature of the income, circumstances in which the income was derived, the stated intentio .....

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..... gement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of [the Agreement]. - - statute, statutory provisions legislation, law, enactment, Acts, Rules, Regulations, Taxation Tax Management India - taxmanagementindia - taxmana .....

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