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.... With respect to sub-paragraph (c) of paragraph 1 of Article 3 1. The term "tax" shall not include any amount which is payable in respect of any default or omission in relation to the taxes to which this Agreement applies or which represents a penalty. With respect to proviso to sub-paragraph (j) of paragraph 2 of Article 5 2. It is understood that an enterprise covered therein will be....

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....part of the profits of the permanent establishment. With respect to paragraph 3 of Article 7 4. With regard to a permanent establishment in India, it is understood that, the executive and general administrative expenses incurred outside India which will be allowed as a deduction in determining the profits of the permanent establishment shall be the least of the following amounts: (a....

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.... 5. It is understood that the expression "in the same circumstances", refers to taxpayers (individuals, legal persons, partnerships and associations) placed from the point of view of the application of the ordinary taxation laws and regulations, in substantially similar circumstances both in law and in fact. Amongst other things this means that a national of one of the States, resident of a thi....