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.... Zambian tax, as the context requires, but shall not include any amount which is payable in respect of any default or omission in relation to the taxes to which this Convention applies or which represents a penalty imposed relating to those taxes ; (c) the term "person" includes individuals, companies and all other entries which are treated as taxable units under the taxation laws in....

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.... in respect of India : all individuals possessing the nationality of India and all legal persons, partnerships and associations deriving their status from the law in force in India ; (ii) in respect of Zambia : all individuals possessing the nationality of Zambia and all legal persons, partnerships and associations deriving their status as such from the law in ....