Agreement between Government of India and the Government of the United States of America

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....ernment of the United States of America have concluded an agreement through exchange of letters as set out in the Annexure hereto for the modification of the Agreement entered into by the said Governments, for the avoidance of double taxation of income of enterprises operating aircraft; Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), a....

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....nts be covered by the note. For this reason we wish, by this letter, to confirm the U. S. statutory requirement that the aircraft, income from the operation of which is exempt from U. S. income-tax, be registered in India, which grants an equivalent exemption to U. S. Corporations and to U. S. citizens non-resident in India in respect of income from the operation of aircraft registered in the U....

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....ax exemption. In this connection the text of the U. S. note does not make a specific reference to the aircraft registration requirement contained in section 872(b)(2) and 883(a)(2) of the U. S. Internal Revenue Code of 1954, as amended, though it had been intended that these requirements be covered by the note. " For this reason we wish, by this letter, to confirm the U. S. statutory requiremen....