Central Government is satisfied that it is necessary and expedient of income-tax in favour of any person, being a foreign company, or a person Central Government has entered into an agreement for the association or participation of that Government u/s 293A

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.... (Department of Revenue) New Delhi, the 6th July, 1987 NOTIFICATION INCOME-TAX G.S.R. 645(E) - Whereas the Central Government is satisfied that it is necessary and expedient so to do in the public interest to make reduction in rate in respect of income-tax in favour of any person, being a foreign company, or a person (other than a company) who is non-resident, with whom the Central ....

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....tal income shall be --- (i) the aggregate of the income-tax payable by him in accordance with the provisions of clause (a) on the profits and gains referred to in that clause included in the total income, plus (ii) the amount of income-tax calculated on the amount of total income as reduced by the amount of profits and gains referred to in clause (a), at the average rate of incom....