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Agreement with foreign countries or specified territories and adoption by Central Government of agreement between specified associations for double taxation relief.

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.... the agreement. (2) Any specified association in India may enter into an agreement with any specified association in the specified territory for the purposes mentioned in sub-section (3) and the Central Government may, by notification, make such provisions as may be necessary for adopting and implementing such agreement. (3) The agreement mentioned in sub-section (1) or (2) may be entered for- (a) the granting of relief in respect of- (i) income on which income-tax has been paid both under this Act and income-tax in that country or specified territory, as the case may be; or (ii) income-tax chargeable under this Act and under the corresponding law in force in that country or specified territory, as the case ....

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....eement applies, the provisions of this Act shall apply to the extent they are more beneficial to that assessee. (5) The charge of tax,-- (a) in respect of a foreign company at a rate higher than the rate at which a domestic company is chargeable; or (b) in respect of a company incorporated in the specified territory at a rate higher than the rate at which a domestic company is chargeable, shall not be regarded as less favourable charge or levy of tax in respect of such foreign company or such company incorporated in the specified territory, as the case may be. (6) Irrespective of anything contained in sub-section (4), the provisions of Chapter XI shall apply to the assessee, even if such provisions are not b....

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....te on which the said agreement came into force. (8) An assessee, not being a resident, shall be entitled to claim any relief under an agreement mentioned in sub-section (1) or (2), only when-- (a) a certificate of his being a resident in any country or specified territory, is obtained by him from the Government of that country or Government of that specified territory, as the case may be, and (b) he provides such other documents and information, as prescribed. (9) In this section,-- (a) "specified associations" means any institution, association or body, whether incorporated or not-- (A) functioning under any law for the time being in force in India or the laws of the specified territory; and ....