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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- Order u/s 69 of the CGST Act has to be communicated before arrest of person concerned– SC
- Refund can not be denied on the ground that it was claimed in a return filed u/s 148 – ITAT
- Distinction between religious & charitable purposes is determined by institution’s primary or dominant object
- Fit case to issue notice u/s 148 – Relevancy of material & application of mind to objections important
- AO is under an obligation to assign reasons for rejecting explanation of the assessee
