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....ing which form an integral part of the Agreement: 1. With reference to paragraph (1d) of Article 3 : It is understood that the term "tax" should not include any penalty imposed for non-compliance of the laws and regulations relating to the taxes to which this Agreement applies. 2. With reference to Article 8, the exemption shall also include : (i) in China, the ....

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.... (F) the China Investment Corporation; (G) any other institution wholly owned by the Government of China as may be agreed from time to time between the competent authorities of the Contracting States; (ii) in the case of India: (A) the Export-Import Bank of India; (B) the National Housing Bank; (C) the India Infrastructure Finance Company Limit....