TMI BlogAgreement between the Government of India and the Government of the United State of America for the avoidance of double taxation of income of enterprises operating aircraftX X X X Extracts X X X X X X X X Extracts X X X X ..... Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), and section 24A of the Companies (Profits) Surtax Act, 1964 (7 of 1964), the Central Government hereby directs that all the provisions of the said agreement shall be given effect to the Union of India. ANNEXURE Excellency, I have the honour to refer to the conversations which were recently conducted between representatives of the Government of the United States of America and the representatives of the Government of India relating to the possibility of concluding an agreement between the two Governments with a view to granting the international ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... le years beginning on or after the first day of January, 1976. (3) Either of the two Governments may terminate this agreement by giving to the other Government six months' prior notice to termination in writing and, in such event, the agreement shall cease to be effective for the taxable years beginning on or after the first day of January next following the expiration of the six-month period. (4) The Government of the United States of America will consider this Note, together with your reply confirming that the Government of India agrees, to terms corresponding to those outlined above, as constituting an agreement between the two Governments, entering into force on the date of your reply. I avail myself of this opportunity to renew t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pose, the term " operation of aircraft " shall mean the business of transportation by air of persons, livestock, goods or mail, carried on by the owners or lessees or charterers of aircraft, including the sale of tickets for such transportation on behalf of other enterprises, the incidental lease of aircraft and any other activity directly connected with such transportation. The exemption herein provided shall also apply in respect of participation in pools of any kind regarding air transport. For the removal of doubts, it is clarified that interest on funds connected with the operation of aircraft in international traffic shall be regarded as income from the operation of such aircraft. (2) This agreement shall be applicable with resp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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