https://www.taxtmi.com/acts?id=4474 Article 9 permits inclusion in taxable income where associated enterprises transact on conditions differing from those between independent enterprises, allowing the affected enterprise's income to be adjusted and taxed. If one State taxes such income, the other State must provide an appropriate corresponding adjustment after consulting competent authorities and considering the Agreement. Adjustments are subject to national limitation periods and a general five year time limit, but that limit does not apply in cases of fraud, wilful default or neglect. en-us Sat, 19 Jan 2008 22:45:54 +0530 Thu, 07 Nov 2024 18:22:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=4474 Article 9 permits inclusion in taxable income where associated enterprises transact on conditions differing from those between independent enterprises, allowing the affected enterprise's income to be adjusted and taxed. If one State taxes such income, the other State must provide an appropriate corresponding adjustment after consulting competent authorities and considering the Agreement. Adjustments are subject to national limitation periods and a general five year time limit, but that limit does not apply in cases of fraud, wilful default or neglect. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=4474