S.O. 1442(E).—Whereas, an Agreement between the Government of the Republic of India and the Government of the Islamic Republic of Iran for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income was signed at New Delhi on the 17th February, 2018 as set out in the Annexure to this notification (hereinafter referred to as the „Agreement‟);
And whereas, the said Agreement entered into force on the 29th day of September, 2020, being the date of the later of the notifications of the completion of the procedures required by the respective laws for entry into force of the said Agreement, in accordance with paragraph 2 of Article 30 of the said Agreement;
And whereas, sub-paragraph (b) of paragraph 3 of Article 30 of the said Agreement provides that the provisions of the Agreement shall have effect in India in respect of taxes on income arising in any fiscal year beginning on or after the first day of April next following the calendar year in which the Agreement enters into force;
Now, therefore, in exercise of the powers conferred by sub-section (1) of section 90 of the Income-tax Act, 1961 (43 of 1961), the Central Government hereby notifies that all the provisions of said Agreement, as annexed hereto, shall be given effect to in the Union of India.
ANNEXURE
AGREEMENT
BETWEEN
THE GOVERNMENT OF
THE REPUBLIC OF INDIA
AND
THE GOVERNMENT OF
THE ISLAMIC REPUBLIC OF IRAN
FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL
EVASION
WITH RESPECT TO TAXES ON INCOME
The Government of the Republic of India and the Government of the Islamic Republic of Iran, Intending to conclude an Agreement for the elimination of double taxation with respect to taxes on income without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including also through treaty-shopping arrangements aimed at obtaining reliefs provided in this Agreement for the indirect benefit of residents of third States),
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