Agreement for avoidance of double taxation of income derived from nternational air Transport between the Govt. of the Republic of India and the Govt. of the State of Kuwait

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....ticle 5 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 Agreement between the Government of the Republic of India and the Government of the State of Kuwait for the avoidance of double taxation of income derived from International Air Transport. The Government of India and the Government of Kuwait desiring to conclude an Agreement for the avoidance of double taxation of income derived from international air transport. Have agreed as follows: Ar....

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....nd the " other Contracting State " mean Kuwait or India, as 1[the] context requires; 2[(d) the term "tax"] means " Kuwaiti tax " or " Indian tax " as the context requires; (e) the term " enterprise of a Contracting State " means an airline which is authorised by the Government of that State by a general or special arrangement between the two Contracting States to operate scheduled or non-scheduled flights between or beyond their territories; (f) 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; (g) the expression &q....

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.... contrary is made in this Agreement. Article 5 1. This Agreement shall be approved in accordance with the laws in force in each of the Contracting States. It shall enter into force thirty days after the exchange of letters certifying that the proper procedure was fulfilled in each Contracting State. 5[The exchange] of letters shall take place at New Delhi. 2. The provisions of this Agreement shall have effect in respect of the earnings arising from 1-1-1967. 3. No action would be taken to reopen assessments in respect of the period prior to 1-1-1967. Article 6 This Agreement shall continue in effect indefinitely but either Contracting State may, on or before the thirtieth day of June in any calendar year after the year 1986 give notic....