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.... is clarified that at present, dividends distributed by an Indian Company is exempt from tax by virtue of section 10 (34) of the Income-tax Act, 1961. Accordingly, even though the treaty provides for withholding tax rate of 10%, so long as the present system of taxation of dividends in India continues, there will be no withholding tax from dividends paid by an Indian company to its shareholders. ....

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....its of a similar company of the first mentioned Contracting State, nor as being in conflict with the provisions of paragraph 3 of Article 7. 4. Ad. Article 27 With reference to Article 27, it is understood that in no case shall this Article be construed so as to impose upon a Contracting State the obligation to carry out measures at variance with the laws, administrative practices, or public pol....