The Government of the Republic of India and the Government of the Islamic Republic of Iran entered into Agreement for Avoidance of Double Taxation and the Prevention of Fiscal Evasion
The existing taxes to which the Agreement shall apply are in particular:
(a) in the case of the Islamic Republic of Iran: the income tax;
(b) in the case of India: the income tax, including any surcharge thereon.
The Articles of the agreement deals with various definitions/ taxations on:
Resident
Permanent Establishment
Income From Immovable Property
Business Profits
International traffic
Associated enterprises
Dividends
Interest
Royalties
Fees for Technical Services
Capital Gains
Independent Personal Services
Dependent Personal Services
Directors’ Fees
Artistes and Sportspersons
Pensions
Government Service
Professors, Teachers and Research Scholars
Students
Other Income
Elimination of Double taxation
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- Mere carry forward of loss can not be denied for belated return – ITAT
- Sales duly recorded in books & VAT returns, can’t be held bogus without cogent adverse material
- ITAT allows Diwali expenses incurred by assessee as business expenses
- Section 292BB does not bar assessee to raise objection for non issuance of notice u/s 143(2) – SC
- Supreme Court explains expression “reason to believe” & “change of opinion” in Income Tax Act 1961
