विदेशी देशों के साथ समझौते
CHAPTER IX
DOUBLE TAXATION RELIEF
56 [Agreement with foreign countries.
57 90. 58[(1)] The Central Government may enter into an agreement with the Government of any country outside India—
( a) for the granting of relief in respect of income on which have been paid both income-tax under this Act and income-tax in that country, or
( b) for the avoidance of double taxation of income under this Act and under the corresponding law in force in that country, or
( c) for exchange of information for the prevention of evasion or avoidance of income-tax chargeable under this Act or under the corresponding law in force in that country, or investigation of cases of such evasion or avoidance, or
( d) for recovery of income-tax under this Act and under the corresponding law in force in that country,
and may, by notification in the Official Gazette, make such provisions as may be necessary for implementing the agreement.]
59 [(2) Where the Central Government has entered into an agreement with the Government of any country outside India under sub-section (1) for granting relief of tax, or as the case may be, avoidance of double taxation, then, in relation to the assessee to whom such agreement applies, the provisions of this Act shall apply to the extent they are more beneficial to that assessee.]
56. Substituted by the Finance Act, 1972, w.e.f. 1-4-1972.
57. For notified agreements for avoidance of double taxation, refer Taxmann’s Direct Taxes Circulars, 1994 edn., Vol. 1, pp. 1.1051-1.1382 and Vol. 2, pp. 1.1383-1.1814; and Taxmann’s Yearly Tax Digest & Referencer, 1995 edn., pp. 6.112-6.176, 1996 edn., pp. 5.93 to 5.158 and 5.181 to 5.197 and 1997 edn., pp. 5.66 to 5.200.
See also Circular No. 333, dated 2-4-1982, Circular No. 638, dated 28-10-1992, Circular No. 659, dated 8-9-1993, Circular No. 682, dated 30-3-1994 and Circular No. 734, dated 24-1-1996. For details, see Taxmann’s Master Guide to Income-tax Act.
For relevant case laws, see Taxmann’s Master Guide to Income-tax Act.
58. Renumbered by the Finance (No. 2) Act, 1991, w.r.e.f. 1-4-1972.
59. Inserted, ibid.