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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....ified 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 under this Act and income-tax in that country or specified territory, as the case may be have been paid; (ii) income-tax chargeable under this Act and under the corresponding law in force in that country or specified territory, as the case may be, to promote mutual economic relations, trade and inves....

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....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 beneficial to him. (7) Where, any-- (a) term used in an agreement entered into under sub-section (1) or (2), is defined under the said agr....