The Gazette of India
EXTRAORDINARY
PUBLISHED BY AUTHORITY
PART II—Section 3—Sub-section (i)
No. 326] NEW DELHI, WEDNESDAY, OCTOBER 24, 1979/KARTIKA 2, 1901 SeparatepagingisgiventothisPartinorderthatitmaybefiledasaseparatecompilation
T266 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(i)Jof India and the Government of Finland concerning the Avoidance of Double Taxation of Income signed :i* New Delhi on the 23rd June, 1961 ;
Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 1961 (43 of 1961), and section 24A of the Companies (Profits) Surtax Act, 1964 (7 of 1964), the Central Government hereby directs that the provisions of the said Letters of Exchange shall he given eifect to in the Union of India.
ANNEXURE
hxcellency,
I have the honour to refer to the Agreement between the Government of India and the Government of Finland con- cerning the Avoidance of Double Taxation of Income signed at New Delhi on the 23rd lune, 1961, and to propose on behalf of the Government of India the deletion of puraaraph 14) of Article VI thereof which reads as follows :
"This Article shall not, in the caie of India ulTccl the provisions of Sections 44A and 44B of the Indian Jncome-tax Act, 1922 relating to the assessment of profits from occasional shipping or trump steamers. When an adjustment is to be made under Section 44C of the Indian Income-tax Act, 1922 in the case of occasional shipping or tramp steamers, the provisions of paragraph (2) will apply,"
If the foregoing is acceptable to your Government, this note and your Excellency's note of acceptance on behalf of the Government of Finland will constitute an amendment to the said Agreement and the Agreement as amended shall be applicable in respect of any assessment year commencinn on or after the first day of April, 1976.
Accept, Excellency, the assurances of my highest considera-
tion .
Sd. !•
G, RAMACHANDUAN, Secy.
Her Excellency Miss Riitta Oro Ambassador of Finland in India, New Delhi.
Embassy of Finland
New Delhi, the 16th August, 1979
Sir,
1 have the honour to refer to the Agreement between (he Government of Finland and the Government of India con- cerning the Avoidance of Double Taxation of Income signed at New Delhi on 23rd June, 1961, and the proposal of the Government of India to delete paragraph (4) of Artide VI thereof, which reads as follows :—
"This Article shall not, in the cage of India affect the pro- visions of Sections 44A and 44B of the Indian Income-tat Act, 1922, relating to the assessment of profits from occasi- onal shipping or tramp steamers. When an adjustment is to be made under Section 44C of the Indian Income-lax Act, 1922, in the case of occasional shipping or tramp steamers, the provisions of paragraph (2) will apply".
I am pleased to inform you that the Government of Fin- land accepts the proposed amendment of the relevant provi- sions in the DTA Agreement as given above. The Agreement as amended shall be applicable in respect of any assessment year commencing on or after the first day of AprflT-1976.
Accept, Sir, the assurances of my high consideration.
MINISTRY OF FINANCE
Sd./-
(Department of Revenue)
RnTTA ORO, Ambassador of Finland NOTIFICATION
New Delhi, the 22nd October, 1979
INCOME-TAX
Mr. G. Ramncbandran, Finance Secretary Ministry of Finance, Government of India, New Delhi.