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..... o have effect : (a) in Canada : (i) in respect of tax withheld at the source on amounts paid or credited to non-residents on or after the first day of January in the next following calendar year; and (ii) in respect of other Canadian tax for taxation years beginning on or after the first day of January in the next following calendar year; (b) in India : (i) in respect of income arising .....

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..... sion with respect to Taxes on Income and on Capital, the undersigned have agreed upon the following provisions which shall be an integral part of the Agreement : 1. It is understood that the term fiscal year in relation to Indian tax, means previous year as defined in the Income-tax Act, 1961. 2. It is understood that the provisions of paragraph 1 of Article 6, also apply to income, other than .....

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..... uring that other taxable year. 4. With reference to Article 13, it is understood that the term alienation includes a transfer within the meaning of Indian taxation laws. 5. It is understood that nothing in the Agreement shall be construed as preventing a Contracting State from imposing a tax on amounts included in the income of a resident of that Contracting State with respect to a partnership .....

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