Agreement and Protocol between the Republic of India and the Government of the Democratic Socialist Republic of Sri Lanka for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income
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....IFICATION NO. 88/2026 New Delhi, the 16th July, 2026 (Income-Tax) S.O. 3926(E).- Whereas, a Protocol amending the Agreement between the Republic of India and the Government of the Democratic Socialist Republic of Sri Lanka for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, was signed at New Delhi on the 16th day of December, 2024, as....
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....effect in India in respect of income derived in any fiscal year beginning on or after the first day of April next following the calendar year on which the Agreement enters into force; Now, therefore, in exercise of the powers conferred by sub-section (1) of section 159 of the Income-tax Act, 2025 (30 of 2025), the Central Government hereby notifies that all the provisions of said Protocol, as a....
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....inafter referred to as "the Agreement"). Have agreed as follows: ARTICLE 1 The Preamble of the Agreement shall be replaced by the following: "The Government of the Republic of India and the Government of the Democratic Socialist Republic of Sri Lanka, desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes ....
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.... to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of this Agreement." ARTICLE 3 1. The Contracting ....
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