Agreement between the Government of the Republic of India and the Government of the People's Democratic Republic of Yemen for the avoidance of double taxation of income derived from International Air Transport

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....equired by Article 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. [F. No. 510/1/87-FTD/Notification No. 8070] P. K. APPACHOO, Jt. Secy. ANNEXURE AGREEMENT BETWEEN The Government of The Republic of India AND The Government of The People's Democratic Republic of Yemen FOR The Avoidance of Double Taxation of Income Derived From International Air Transport The Government of the Republic of India and the Government of the People's Dem....

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....al air 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; (e) the term "operation of aircraft" means the transportation by air of passengers, livestock, goods or mail carried by the owners or lessees or charterers of aircraft, including the sale of tickets for such transportation, the incidental lease of aircraft including on a charter basis or any other activity directly connected with such transportation; (f) the term "competent authority" means: (i) in the case of the People's Democratic Republic of Yemen, the Ministry of Finance or its authorised representative; (ii) i....