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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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.... 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 Government has entered into an agreement for the ....

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....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 income-tax which would have been applicable to the total income, if the provision of the ....