Agreement definition requires both a tax-treaty instrument and a notified report-exchange agreement to engage the tax provision. For the purposes of section 286(9)(b) of the Income Tax Act, 'Agreement' means a combination of: (i) an agreement entered into under subsection (1) of section 90 or subsection (1) of section 90A; and (ii) an agreement for exchange of the report referred to in subsection (2) and notified by the Central Government.
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Provisions expressly mentioned in the judgment/order text.
Agreement definition requires both a tax-treaty instrument and a notified report-exchange agreement to engage the tax provision.
For the purposes of section 286(9)(b) of the Income Tax Act, "Agreement" means a combination of: (i) an agreement entered into under subsection (1) of section 90 or subsection (1) of section 90A; and (ii) an agreement for exchange of the report referred to in subsection (2) and notified by the Central Government.
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