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Delay in obtaining the finality certificate from the Ceylon income-tax authorities.
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....onclusion of a double taxation avoidance agreement between the two countries. The relevant portion runs as below:- "....the assessment orders of Ceylon should ordinarily be accepted subject to such adjustments as may be called for on account of difference in the provisions of the Indian Income-tax Act and the Ceylon Income-tax Law". Relying on the above instructions, double Income-tax relief und....