Protocol

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....e Government of the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, the undersigned have agreed upon the following additional provisions which shall form an integral part of the said Convention. It is understood :- (a) that, with reference to Article 7, paragraph 3, the expression "expenses which are incu....

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....to the Italian State Post undertaking (PP.TT.), to the Italian Foreign Trade Institution (I.C.E.), to the Italian Tourism body (E.N.I.T.), and to any corresponding Indian body or institution, are covered by the provisions concerning Government service and, consequently, by paragraphs 1 and 2 of the aforesaid Article. Other public bodies or institutions may also be included in the precedin....

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....ion which may subsequently be made granting an exemption or reduction from tax which is agreed by the competent authorities of the Contracting States to be of a substantially similar character, if it has been modified only in minor respects so as not to affect its general character; (e) that, with reference to Article 26, paragraph 1, the expression "notwithstanding the remedies prov....