TaxTMI 
TaxTMI 
TaxTMI 
Agreement for avoidance of Double Taxation of income of Enterprises operating Aircraft between the Government of the Republic of India and the Government of Ethiopia
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....n Ethiopia and India respectively, as required by paragraph 1 of Article 3 of the said Agreement; And whereas the letters to this effect have been exchanged between the said two Governments, as required by paragraph 1 of Article 3 of the said Agreement; Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), and section 24A of the Companies (Profits) Surtax Act, 1964 (7 of 1964), the Central Government hereby directs that all the provisions of the said Agreement shall be given effect to in the Union of India. Annexure 3[AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE PROVISIONAL MILITARY GOVERNMENT OF SOCIALIST ETHIOPIA FOR THE AVOIDANCE OF DOUBLE TAXATION OF INC....
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....services; or (ii) an airline which is authorised by the Government of that State by a general or special arrangement between the two Contracting States to operate chartered flights between or beyond their territories; (e) the term "international traffic" means any transport by an aircraft operated by an enterprise of a Contracting State, except when the aircraft is operated solely between places in the other Contracting State; and (f) the expression "operation of aircraft" means a business of transportation by air of persons, livestock, goods or mail, carried on by the owners 7[or lessees] or charterers of aircraft, including the sale of tickets for such transportation on behalf of other enterprises and any other a....
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....Contracting State. The exchange of letters shall take place at Addis Ababa as soon as possible. 2. This Agreement shall have effect: (a) In Ethiopia, in respect of income derived from the operation of aircraft in international traffic after 1st July, 1966. (b) In India, in respect of income derived from the operation of aircraft in international traffic after 1st July, 1966. Article 4 This Agreement shall continue in effect indefinitely but may be terminated by either of the Contracting States with a written notice of six months. In such event, the Agreement shall cease to be effective in respect of income derived from operation of aircraft in international traffic after the 1st day of January next following the date on which the sai....
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....within six months from the date on which the Agreement aforesaid enters into force, and any proceedings already initiated for the taxation of such income shall be terminated. (2) Air India being an enterprise of India, any taxes paid by it or any deposits made by it towards its tax dues in Ethiopia in respect of its income for which it is exempt from tax in accordance with the Agreement aforesaid shall be refunded by the Government of Ethiopia to Air India on an application in this behalf by Air India within six months from the date on which the Agreement aforesaid enters into force, and any proceedings already initiated for the taxation of such income shall be terminated. I shall be grateful if your Excellency will confirm your agreemen....
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....iated for the taxation of such income shall be terminated. (2) Air India being an enterprise of India, any taxes paid by it or any deposits made by it towards its tax dues in Ethiopia in respect of its income for which it is exempt from tax in accordance with the Agreement aforesaid shall be refunded by the Government of Ethiopia to Air India on an application in this behalf by Air India within six months from the date on which the Agreement aforesaid enters into force, and any proceedings already initiated for the taxation of such income shall be terminated. I shall be grateful if your Excellency will confirm your agreement with the position as stated above and, in such case, this note and your Excellency's reply thereto shall be d....