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Agreement for avoidance of Double Taxation of income of enterprises operating aircraft between the Government of India and Government of Afghanistan

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..... n 90 of the Income-tax Act, 1961 (43 of 1961), ad section 24A of the Companies(Profits) Surtax Act, 1964(7 of 1964), the Central Government hereby that all the provisions of the said Agreement shall be given effect to in the Union of India. ANNEXURE Ambassador of India , Kabul , September 14, 1975 . Excellency, I have the honour to refer to refer to the Agreement dated the 26th January, 1952, between the Government of India and the Government of Afghanistan relating to air services, and to the discussions between the representatives of our two Governments on the reciprocal exemption of the airlines of India and Afghanistan from pay .....

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..... tan tax " means the Income-tax and the business transaction tax imposed by the Income-Tax Law of Afghanistan (c) The terms " Indian tax " and " Afghanistan tax " shall also include any identical or substanitally similar taxes which are imposed thereafter by India or Afghanistan in addition to or in place of the existing taxes. (d) The term " airlines of India " or " airlines of Afghanistan " means- (i) airlines designated by the Government of India or the Government of Afghanistan, as the case may be, in pursuance of the Agreement dated 26th January, 1952) as amended or revised from time to time), between the two Governments relating to air services; or (ii) airlines which are authorised by the Government of India or the Government .....

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..... r year following the calendar year in which the notice is given and the subsequent assessment years; and (b) in Afghanistan in respect of income assessable for the taxable year commencing on the 1st f Hamal, corresponding to the 21st day of March, in the second calendar year following the calendar year in which the notice is given and the subsequent taxable years. I avail myself of this opportunity to renew to Your Excellency the assurances of my hightest consideration. ( Sd. ) K. R. P. SINGH, Ambassador of India in Afghanistan , Kabul-Afghanistan. H. E. Mr. Sultan Mahmood Ghazi, President, Civil Aviation and Tourism Authority, Kabul-Afghanistan. September 14, 1975 . President Civil Avia .....

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..... liable to the aforesaid period has been recovered by either Government as of the date of this Agreement, the same shall be refunded by that Government on an application to be made in this behalf within twelve months of the said by the airlines of India or the airlines of Afghanistan, as the case ma be. (5) It is understood that: (a) The term " Indian tax " means the Income-tax and surtax imposed under the tax laws of India. (b) the term " Afghanistan tax " means the Income-tax and the business transactions tax imposed by the Income Tax Law of Afghanistan. (c) The terms " Indian tax " and " Afghanistan tax " shall also include any identical or substantially similar taxes which are imposed hereafter by India or Afghanistan respectivel .....

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..... unless either of the Governments gives notice to the other Government of its intention to terminate this agreement on or before the thirtieth day of June in any calendar year after the year 1980. In the event of such a notice, this agreement shall cease to be effective: (a) in India, in respect of income assessable for the assessment year commencing on the 1st day of April in the second calendar year following the calendar year in which the notice is given and the subsequent assessment years; and (b) in Afghanistan, in respect of income assessable for the taxable year commencing on the 1st day of Hamla, corresponding to the 21st day of March in the second calendar year following the calendar year in which the notice is given and the sub .....

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