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....: 1. It is understood that the term 'fiscal year' in relation to Indian tax, means 'previous year' as defined in the Income-tax Act, 1961. 2. It is understood that the provisions of paragraph 1 of Article 6, also apply to income, other than capital gains, derived from the alienation of immovable property. 3. It is understood that where an enterprise of a Contracting State has a ....

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....9; within the meaning of Indian taxation laws. 5. It is understood that nothing in the Agreement shall be construed as preventing a Contracting State from imposing a tax on amounts included in the income of a resident of that Contracting State with respect to a partnership, trust, or controlled foreign affiliate, in which he has an interest. IN WITNESS whereof the undersigned, duly authorised to....