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....ear after the expiration of five years from the year in which the Convention entered into force. In such event, the Convention shall cease to have effect : (a) in India, in respect of income derived during the "previous years" beginning on or after the first day of January of the calendar year next following the calendar year in which the notice is given; (b) in Thailand, in respect of incom....

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.... Memorandum of understanding with respect to the Double Taxation Convention between the Kingdom of Thailand and the Republic of India. It is understood that : 1. The term "tax" as defined in paragraph 1(d) of Article 3 of this Convention shall be interpreted not to include any amount which is payable in respect of any default or omission in relation to the taxes to which this Convention appl....