Agreement between the Government of the Republic of India and the Government of Yemen Arab Republic for the Avoidance of Double Taxation of income derived from International Air Transport

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....w, 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 YEMEN ARAB REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION OF INCOME DERIVED FROM INTERNATIONAL AIR TRANSPORT. THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE GOVERNMENT OF YEMEN ARAB REPUBLIC DESIRING TO CONCLUDE AN AGREEMENT FOR THE AVOIDANCE OF DOUBLE TAXATION OF INCOME DERIVED FROM INTERNATIONAL AIR TRANSPORT. HAVE AGREED AS FOL....

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....t operated by an enterprise of a Contracting State, except when the aircraft is operated solely between places in the other Contracting State; (e) the expression "operation of aircraft" means the business of carriage by air of passengers, livestock, goods or mail carried on by the owners or lessees or charterers of aircraft including the sale of tickets for such transportation on behalf of other enterprises, the incidental lease of aircraft and any other activity directly connected with such transportation. 2. In the application of the provisions of this agreement by one of the Contracting States, any term used but not defined herein shall, unless the context otherwise requires, have the meaning which it has under the laws in f....