Notification: 14 Date of Issue: 21/2/2013

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PART [—Section 3—Sub-section (ii) : ; a wrftrene 8 wentfore Se
. PUBLISHED BY AUTHORITY |
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2 | THE GAZETTE OF INDIA : EXTRAORDINARY [Parr 1—Sec. 3(ii)} | | |

ST ara 1 at & vide F det mae F oRer aie ;

RO ww ot G dds X Aer wuss S wRex ay word aude at;
Wert & fy cer Sai sat } ate one weds at ager Bw fe aw,

SR PTT SRT GT gear SB, Pega WERT Ee: |

; re TY - 1 |
Te RW aferat wary ern wl Ufaarort wet FU fat ww
| ara a & Pranet & | - | |

7 | BT - 20
4. We ee fort diaert woe sern sad wee sere seat
. Tria safer ER Ss WY oy WE aR S Wael A ary etm, we F fre

. - [amt Ta 3(4i)J oe SRT ATAU: SRT 7 | 0 Ls
7 Tet aR are Wak S skrer S ora afar wom aya ae ee |
vem aI wen Tage sea aa at Ha wal we ae afer Go arg aera |
ae @ aa wore ay at ari oie aR a aa we ae ae aH STF oo |
I aeTt |
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- @) ARTA, area fret Ta ae ory Tet aferre aft enftar 2. | | .
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| . prerenal BMT BT WR BX ; ; | ae
| (fra sae ate “srt wr" wear | ; iG
4. We RR fret afl ae aera aera: GA aR UA Ty eT GY a .
WwW eee fey wy at ante & wa fier a & faked sera was :
RM Wane we | eae well BS wer wien fers A aecage
Ratt & ddr Fo wwe Gay at afga att a was ae owe .
orga 4 fey ay et | | |
1. 3 RR @ warrant wa dw dat A aren sia 3 Br: Co
~ (@) axa’ wa @ afta & - ana ar aoeda oie eae conde _—
WR ik Sas GR F appisety aa S afaRad we Wt sry | —
wat aa waite 3 fad a on weg ay We

4 THE GAZETTE OF INDIA ; EXTRAORDINARY [Parr Il—Sec. 3(ii)] | 7
vs B WPT WIT sll sree sare den aaa s ; gy gftrettan sax arta & gente edt ater more
| 7 | sie afe yfaent ef 4 vam fear arg at sae sri weitg i 7 tn aa ok ar oer aa 8 get saws oT G aR,
; | | gum ghar & arp G arpa & aera ga WS aa Hw A
| oe venta fea or wed & fret sPrifiea seat wpa wa
. after aera dart ar war we & |
| Ht MATER AR TRIE aera dels adits gratia z ; teat wer ug Hag aS, aE war, afte aA até der
. ° GMI Sri & det vo Heda garg & wr i MAT wns;
: (3) ‘oer wed ag Pata Pore sera otf wen afin BBR
| , aX was & fag ce fafa Pars G we A aT UT a a an )) ‘ser waz fort gon & SNA BBE aT aT ; .
7 os @ "ye different usr ot vert wen ‘eax ufterert aor oT ver"
lS Vey cen ae tifdarent doy & fort Prat gra warfera
' ows vem after d;
| (@) ‘area aera" wel & afta % - ve gent wae
. fort ser ari uRanfera fet cera steal aga ari wRaes, fray ve fer & wa THI Ha TIM Set HN
| fda wero wrt & ata SF wera ore z ; a) Taare arftrmret* raz aaftrter &
| | (i) ana & amd # : fer th, ane WOR sear Tee

. tr IBS 3(ii)] | | ING BI TAG: SATA ; 5
a | Gi) Sift S ama 4: Ae oie wee we)
(3) feet iftcrent wor $ aa Fae wer S afta Bs :
' (i) feet co efter wea BW alee are wet ara ; _
; (i) aig Paes aafaa, aftert atte when, fore one ge TRE a
# éftaa fet daaet wa Aye arp a ara | {
, @ ‘m' we B dat S age aete a see gifts a 7
-_ attire % eq gwd Oh ag wea enftra aa ehh, ch oa a |
| @ dae 4 fot Yor sera yw S Gad 4 eq a, fort we ae Ge aL eet at ora wt ae @ dda F amy ay selds sea | 7
| (3 ‘fade at’ wed afitia é : —— | |
@ ard BAT A: Uw onter W omer BA aren Raetha ae a |
Gi) Brett B ara A 8 Gers BL orey 2A TreM a
—s fret different wes grr Wet ad se Gee at ary fey oF aT wea | |
wa ae dat @ aren ster a a, Tat afeanfea ford wea ar cat aref ern
Ba at F pat S fag Sa ww, fora wy as Ha aNy ala 8, S arp
@ tefa va waa erat @ alk Ue oef wa eT any fe GM ae er orp .
8 deta ere ay aed we ward eon WH Va Tee SG oR or @ seria TMG |
7 GEMS-2- | - | _ :
| | |

| 6 THE GAZETTE OF INDIA : EXTRAORDINARY (Part Il—Sec. 3(ii)] : |
. a : WTO - 4 oo
; 4. Ba Ss ware “we dared wor ar Pah” we or oef feet wa ated Ue ha WK ve wea S orp & sitta Tas aiffare, Pare,
Pra @ RIM, ween sera fet ta Gf ora 8 Hr ama W UEa z
Wan at mea a, ant sq wet or ten afta wfta aet enn fre we bat va we a Re Ad Ve ah wa Rw wt RwaM A
2 wat hmm 1d cade 3 one a as aaa aot A dae oT
Oo ot Ranft &, set saat etree Perper aa ot are : Po
7 mS) «8609Be Gag ott wey a Pani wT WET vel VS We wee
Para-ye wyetel et; afe oe ai at wool F arg wret Pare
_ Te wee e A de ve wee wt Ue Pranh aa orem, rae
. a ae san afeira sik ante ddr uProa & (recaqel fect ar
. oR);
- @) afew wee of fires wee seca fea Pfea & Paka ae
. far UT WH a sera ae ss dat weal A a fHeet Ht wer F
ale wet fare sree vel eB a ae Te UW a
Fart arr orem fire ge sreaa xeat 2
= a afe ae snes Si a weal 4 vem a sera oad S foe A
we F qe wea a, AW ae va wa o fart ant we
| foray Te UH UieH z : .
m «6 ae ae a at weet or whew a aera oad @ feet at weg
7 _ or Ufea vel a at dftarent wal S wars oiffrert geaRa
, wena ERI sa wea wT Pots wet |
- 3. Wet Sw aes S teas 1S wade S or fort ale a fs wy d _

(9M eve 3(i)] SR BUST: TATE . 4 a
| ore fore See wat wae wart fra & | ae wa ea wr Puke set fear |
OT Gea et ret seer ward wdr wars fra s at fart weal Saar |
TRS mR wes 8 Fa wet aT WTI He | a
. | oe | BYES - 5 oe ae
4.0 Be aA woef emt dens ve a onwa onan d a .
Pitas ws & @ fread are fret ser or arta wpa: sera signa: feat
, TIM & | OS ,
2, eeret terest ve & fasrraar Prafetter era eft :- | |
| (6) da or ag wT | | . |
. | (@ Bere; a a _ |
| : (7) arg orate: a | Co — -
BE eRe ; | a (F) wry srienen ; . a .
_ @) ag tt ox, oO :
(3) feet fda @ daft ats aero aut ot awe Yer |
_ (@) mg Or, ara sera oq wi sel fe, afte, arrart oS GF, Ga sera Ae or Hail, wars sen orp Waal &
| Preptot a pty sry el . _
— 3 (po) até Hosea aera Prato, memes sera Wale oRaloray sera - -
sued Weta eet orion wt ve wrt dent som ale 4
. |.

| 8 THE GAZETTE OF INDIA ; EXTRAORDINARY [Parr II—Sec. xi)
Ra wa, URetorT sera orfsars 183 Ra aw see afte yO WY IG Tal . ’
@) Wat nes oe, RRA ge wes Bq erm A ah ey oriental
. ; sa ser aiiiet @ araq O fet sea at weet sag |
afte & veg vet Te we S fora fret 12 FEA A
Oo wate @ fae pa Petey ve veh St aah a sraftral & fay a al @ Fhe ore vec ef (Sel aera tse Tato eq) |
| 4. SH ae S ydadt wade @ ae ee MM ot dem” uF
: a) Sem waiter aa aera Uae B ara Ren, wes
| wares glans wr SRA Bet ; OF
(@) Aa Wesry, yess w Warne vers UY Walla Ara aera yor
| Teal & fed tie Hr w-ward HET ;x
@) «fet ser ver an tae delaa foe aA @ aR ve
@ AeA Mera WA-aeEyail Bs Wha Hl WII HT ;

. (@) van @ fae ma set wea a daa wa ae S fay wad Yan waa ae o fy ora o fed Aaa era a
| Wa-WaN FET ; |
) ver @ fay daa onfers ser wero wae @ feat omy

HaHa Bt Tar & raed ora & fag Akad eI a
VERT GE ; |
— @) sehr @) a () ae 4 ofeafta daa fort? orl-oarci
. oe wine @ fy qa & fodl fiRaa wire a wG-waTa
| ee, an fe 2a dio & cRomeen ona @ fafa

. [WT 1——@WS 3(ii)) A AT TTT: STATURTT . . , 9 : 7
. ; TIM a Wet ered feet weft a were eret wT at | . 4
_ 5. femme 1 otk 2 & unde S ea gy Ah ei waa ahaa S feet a afr, fire 1 RNS 7 ar] ea a, 4 re ets ales ay aitarert Wor feet ser ot ate S vw tieareret we 4 ord grea & dei Sa Bredqorst
@ tide 4, firs var afer vert @ fae wen & wemifceftsa aiaart wT
4 aa ven 3 wR He eT A oT, BR a
—_ (@ ) oa wet Oa & ow wer 4 de GE aA TT eR
: oS wet a afk ae sneda Se Miter aT wary a He Bl, Ua TH
— fe RS cafes a afafetat ers 4 4 fear a4 afafetert ae vifta a et fire aff ce onan & we fied eit @
Tear SO wa arate Hl Ga ary S sada @ aT Gia
Be & oa Pfgad eis of ae welt eM Ael TAT, Sera oo (@) va ag mor oa we a fey ae fee A sna
. weifeead weer A U8 are sera qea-aegaih Gr Kia WaT et
| - firrt S de var wt aie S ara aera cea-qeyait at frafa (7) wed we S fe whe oer aT quia worms
| Wey A seats Hrs Ht SST WT Ha ST | |
a fare sem amr fret wiRterar® wou A ara gw aren wg wre weed art er sai arn orem fe ae ve wa 4 fet aaa, ears ote wie
. gear vada *Rrra aa feet aq wee 3 aay U oar oem & aad fe te affs aay Gar Gl SA UAT BH S oe we et | aenft, wa US feet gue & oriaeny qua: sera TT Got: SA TE FH sie S fey oe ef, wi aa ge thms & aftr & sicta cada saa wr we set wast OTT | |
7) we ae fe ag rh, ot ww aftaat wor ot Ranft & Rt ot
_ Capt at Rafa aedt & sera fat tet wart grea Rafe edt 2 ot gay
Bearer wee at arf & sera oh oe qek wea 4H (eres feet were et
7 17 GE[F~3 | | ; . _
t , , |

10 THE GAZETTE OF INDIA : EXTRAORDINARY (Part Il—Sc. 3(ii)] | ; | |
| & mea % sea seen) one owt & awa a aa Ai eat a |
a OAR OT wT Res Ae AT TT
1. we Where aoe S feet rat ant qUt aerat wer F fra
- rer VAT GMT STW TA GaN Ver FH ot GGT | _
| srr a ue ar oef aft hn ot ow tat wes os
_ seis waar set s forert frais wate fara fo 1 sa ve a, feet at acta
. 4, a wfta eM - saat waa & aan S ws A wae Hy sik ahat 4
. Ted og sik wey US afer fr ow peas wat cere or S
| | Sade oy ed ei, saa ware wt are @ affer sik aa WSR Bt a a wpa tae & eet & fey sera ded G aflar G wfawea a wa F
| —oURaa aera fad seraPrat @ ofa wera, ate afk agar staat a wat Bw we A ae A wT |
3 teams 1S Bade, arta waa FS ye Soh, aa feed oe By sera
| sad fod aa var & parr BUTT eA aeit ona Ww A ary a |
| - 4. tene 1 aie 3 & ards, feet vem a oma waft Bou oa an wads alerts Vast > Pract & fey ayaa ataet raf B wrt ara Ww a At ary ert |
ge aera ame SB fit ser Sanit a daa TA wT A a
| det 3 mea 8 oa we 4 onan acl oe a | afe sea sem oT

!
[amr rave 3G) OT BT UTT : SHIT ni ‘
| Te Vane ea ad sss oinakeideaa |
wea t fq sas art S daa oat aa WA KX aT wt we ert :
: PMT BI MTA BT A BT | Lo
- - 2, Rare 3 & wadel S ania wa ge wet ww dont wa a os |
BEA ER Secret wea 4 fera fort weet tenes S areas V Gra Hea
| BS, ta Wake Saat we FS we Her S SRO Ey oy, a A AM oo ae hrs ah Of dren aa eh wa we WAM a see frodi-gad | |
—. ORRER a ve aa a fert-qed oreo 4 ot ey ad sik fis vet |
. Bake ve ves S ae We: eda wT PG oa wer @ fram ae WS
ware wens Fl 7
3. eft writ fem S an & ako om 4 va wear S arp H 7
Tok sadet sik saat Msi S sent wr aal at weld a aaa ore, :
ogg wrt tem é hr ed fer wd & Rei gave ama |
. fet wd gare verafte ag fh enfra & wea A a we wee A ve wT
BR SP S saad stk waat okRenait S sarge fey ay a, rt eet
Pear frat & sera aera fey ay ef | cenit, wel tens arr Ura So
_ dae, J teh fet wehh at anata ae A are ot wet dem ar ver —
Sw sates al seat gad fost arr rafal wt wee sera sa |
aftert & vat & ace 3 wafeedi, Gra sera exit exe Gt ay saat & , wi FY aera ated @ wi 4, fronfea faire Gasit } fy sean wat Sy (aera afr ery |S Met SI visax wet Wenct se ve fey 7 a Ww ara & wr 4 (areas ary HH ofagid & fx) afe wig et, oie rer Gt ag |
_. Wh wad ddr F Ot odd ot agai set ct we set var ve wet oo: 7
| gem S ani a Pako eet y ve wea ew fare 4 at fe we a 7
ward erat ger Serr} vers Grates ot sera sad fart ora orate HT
. Yeel sera sa affert S war & aac 4 wafeeal, wal srerat get we at |
aay saafra & wa 4 sera Premed fare Warsit sera veer & fry Hated ,
@ wo 4 sug fodt te van S aa HI wiser vas seg see feti wg artes & orate wy ot var femme a Sera dae aT
co a ufagfd & fret aa) wRrat wae at ws st a : :
. . . id

; oo : | | . ee . ao
. . ae THE GAZETTE OF INDIA : EXTRAORDINARY | [Part I—Sec. 34)}) |
4 Ue UH Reet wer A oer Ss Ga aT a oes AA
MUTT & STI A Vee Ta ITT BT SF are ory er Par Get a ger
~ @, Fet RET 2 ST Gig at aa Sa dterrt wow FA wafer wa vas
: x aa am o Ruka oe a nftafta vat eet, cenit, wom & far,
"+ amg 7g fae Ge eri fe wear com ga aged 4 fata Rant $
eS ee oe
~ 88 as ory, Bae ga Gro S fre welt ehenes a ger vet aT TET
0 Re oe eared wena a wert & fer are aera qoa-aRGy atta = I :
gach tern & wet wera seerer & wror ge ait Bt ae aw waged wet wait U Palka fear ara vem, wa aw fe sad farta awry -
7 Se cen cater wreor ae Ho
7, wet are a one A tet ae ena att Rie ge GA Ss eT
apa A sent S fares fear en ze Fei ws sypewe] G vada Fa ayaa G
—_ wudet & wants set ett |
. . “ye J ~ 8 7 - |
\ — _ 1. ve Sfiaort war d fet sem ae amrerstty aaa A waar
: WaT aa Fo waters SB ara eh area adi we daa ait wor 4 a aoa
Oo 2. wafe feet were gem or ward wde-wI VE Ue WT BY, de Fa
| we dffarent wer 4 ra aa aren ree aera a ao Fawne fra B
. er ae ca waar wr A wt ag me ween 7 s, A ww va
2 Bfaareert toe 4 err ar ore forte creas wr vere Tar Prareft at |
oe woeardt So oma ory, fart arr ae wr age 6 Rast S few wae

[AMT I—wve 3(ii)] HT HT WITT + TAIT | 3 a (ate Sata, aera ort Gra fry ea (en wea PRs |
. wat, Wawa aera fey we eat, cher Al aren Bl, siete aT A 7 13
We AIT aq S rarest H fay ayy sera ayes). . 7
| i
| 4. apes S gahorne, at sere aaa A wear sea TWyat
@ waa UT waa we aS a te Pag mw ant a WS wea aera agar & wane 8 wd ant @ wr 4 arn orym ale a te ona ay aR oft ef otk sree 11S Vode WS ara @ dda FY ary vat eT .
oS: deo 1 & aude feet ga, fet gad ver oer fee omer
Weert Gor A APT oy S yet aT ae At ATT aT | |
_ 6 we waa 8 fh sa aye GS UTE, ARA TR St MER ak | |
Were faferh wrod sheila at wer f da agai ot dafo ; |
[eet Ta Vert at ora & cet oeert S oRew & fey Po owe fore 4
, > Retin 25 FarR 1976 at aeTER fey ay a, S Suda a1 ofeenfia He | og a 1. Wet - .
(@) we iat wa wats ser gat eat ar SR
Ser & wde, Pea sera Gol A weal: steal sewed: ANT . |
| eat B ; Berar :
(a) ad afta, cw dfacart wea & fet ver sik gar waar |
wey @ fart ser H wae, Pata serar Got A wera: seraq :
7 ae Soh a Ree oH armen H ArH seri} dar ard afte rere Peta daa F Vet ad wt aerar erg Ont at GA wat S rs SF GT cada veri -
TNIGE|I3—4
,
OF | |

M4 . THE GAZETTE OF INDIA ; EXTRAORDINARY [Parr II—Sec. 3(ii)] | .
. tho thatdwaaitaae Ms aa AeRIa oo set He ye ver at ore gn aa, feed oa wal S GR FA FOR we, ,
. so Wet Ban, BW a aH ve ve S a A ae fee wae aR DC
AGAR HX SATA GT WaT | : | . .
ae ew etree ea va werd ARM eS ani dora
— Mffera Gea & ok aaa wr wna & fire we gar afaaranet wey a fore
Sam WT US SR Woy F a onan aM sé ak wat asf fey we ow
— am & Th werifeattet wor GS vers Gr ve Rafa A ura gy aid afe cei ver @ dq omg as wd ve ae ot edt wt aca veri G dia amg 7
a ad, Te Fe FAT Wey oF an we STA eR oe at UY S aaae waa
WNT ST | Se TERS wae oe Af oe A se RF aT
_ waa ot aif wy SY ar F we erm sie ate sravam si, al wiraert
| weet BS Mert HTH ver SAH Uret yeiael pe) | ee
7 ml, 7 arqeee - 10 : .
1. ae Ufdarart wer at Pari fed wart err gay ufearpnt aor a fret Fart ot ater fou ay aries Sa SEX WRT A HM er |
| 2 went, 3 amie wow Wad we Aho we aes aS
SRR SW eT war fora aA sal SA Tei} Sar vo Prat z, weg afe amir or fear cart oa dfaarert aor or va Fran ¢ a sa
Fer wart ae aia at wea wr ao 5 vfs @ afte set sem | ae
Rare wt aa S dda F Sarl S Hees at wufaa sel oem fort ariel ater fey TY S | .
Sora ara BS a on St arPftaka S aT gS qa a al, sik wey ssant A
oyna ora @ 8 fore We at GUE GaeT ay elit FT VE wer G arp @ |
ste VaR BT wet sa we ary act z, forrat faa wer ae! Sah wH |

| [aT 2205 3669) RE ST TATA; TTT 7 is | 7 |
4. teams 1 ait 2 3 ode va PUR A amy et et, ae areat | |
| feaarht wart wt ya dare wer a fant a S aro gay dae | _
| - We 4 gel dt ws ere tens G areas B Oa oe & forat ara .
FI SM Tet Hert Hart f sera wa gar wou F fra fart Aer wa sat Aafia ard ver oe & oR fora wok @ dda F araiat ot ee
. aeat at unt & ai ge ga yer } wre tem sera ffvad wr |
wad wi 8 wag 3 | te fee a, aqede 7 a age 14, Shen A AEM
8 et aE eA, OY ua Stared Ter a Pah & gHY atarmry |
Wea a AM aera TT ore wR Bel GET WON Sar En stat fy ay a arate oy fet a wor a ex sel ony, wa am fe CH ania sa GaN oy
5 Bee a fet Pare at star fang ort et, serar ora aay fae fore wafer Sark |
a arviet oreert at ort a, ae ge gue wor F fra feat ert sees a feet fad era @ wd we 8 tae 2 aie a & Gat & aftafta ani {
OR BY ONT IGT, we aa fey ae ata sean afaaRa amg we a |
- aifte wr U Se RX asa Fay SA TA aM sag ata GMAT) |
1p eeree wor a GerT AT Ta Fer GR earns me SA
._ frardt et ater fg We arr We Se Fae Wey A aR AMA GT USM | a a
2. — aenft, Se wor S ane woe dae we Ff sik oa MTS |
orl & ar ox cra oT ween feet wor F ae say star @ farg ale
| ara on fern wart gee dae wey a fai ea ga wer wR] |
HY Ma BW MH WA S 10 where S silty set |r | -* a
_ 3. tame 2e vad Sad a we dRaet wasup a

: ‘ we"
“16 THE GAZETTE OF INDIA : EXTRAORDINARY (Parr I-~Sec. 3(i)]
_ SH wey F He a we ws ah aed fH sa Pefefea S at ore fea wa
_ at ok ferarit wa 8 amt eae 4 Yar var at: ys
| = =) @R Reet we A weR sae SE wae veAT -
| @) (i) aa & wna #, acta Rod a ; site ;
| aa Gi) grata & are 4, Aaa de site sfratftar ; aera a) aig omer eters fore oe ear eet S Ate were waa
: ERI VAM Ue Tal H Serva H AIA S Teafa Be er |
: 4. seaqee dan -wgaa “era” wed afta 2 - ses co eT
Wat oral Sara ana, ae ¢ daw grr ofaye ef sera we oy ae vs
RMU-AT BS ATA A anftant ar arg arferaore wea et serat wel et ax fags wa
SO GaN wergferal Borat sia aie daval seat zeor-gat Sora ara fore vet waged, sauat sera socal S walt stftert sie eee ele at |
Rafer aerrh & fry aids dah ani a ga ages S water GS fey ara Tél GAs VIG |
| 5. tam 1 dk 2 6 oye oe fea Fo my ae et, off at a
Rach cari, dfserort wor ar fart et @ gay dfterort wea 4, foreni
; aTeT Varta gM a, waa fare fart welt wenss G wea S ORE Ha et
| HAT GA FAX wor 4, wea fara fet fikad wor a cada daferw Garg
Frenita axa et ak fra aoa & ae 4 ara aa far wa ef ae ga
Tor & wrt deans aera Raa ws V wit wa S was a | VS Aa
A eee 7 sera awe 14S Gude, Se A AeT a, ay eM |
| 6, Sant feet dfaererd wee A saya gen APT orem, aff aa sat ae
Tet Se wer ot Part a | cent, wet art ser ae aret alsa aT, ae ae forft dfaarent woe at frat et sera vei feet afar wer 4 va wire
. Tema sera Pizad wera & alk gu ae A aan fore we ae wee feat TAI

{3rt ave 3(ii)] cea YUAN SETAE | ne |
fh, SAFO aT ae ge ye S wh teres sera PR eI ee ast |
feat WaT & al SA Wa ST aa VE Ig A vaya BT AMT UTE foreat ag |
aR eee sree fafgert wears fea FI .
| - 7% 9 Met, er oer aet afk Ravi wrh sera wa ai @ sta cen fret
. ory afer & ata fas dea aA GS SRT aa wl ws as BH wy, va meet Br ar 4 wae gy fad fog ae won wat Hs & Ta HA Na
Une & foraa tae A Fa THN SG tide sel at G1 fafa A ger Ge act sik
| ferarh cart @ sta wena et ag etd, ae gu areee & soda sift ww S
afta wea wy at ary ett | eS ATA A aarafial S snfles aT we ga aR
ora Bade Hl Ar FH Wad eT ule Ufdcrant wer S Or S aT Hr
STAT BATT | .
_ aga 12
wafeeal Ud carat Vast @ fag whe
4, ga eiRerant er H say AF aes ate gue eared aor as Pet
Frat ot stat ot ws wafeeal a aadiet Gast a fay we w sa GR
Paararet Ws A PX SMTA VM WHAT |
| 2. venti, ga ver at wafeeal a aaiat Varet @ fay gra ww va
Uiaarart wer Ht, Kr a saya ey st, Ta MTS arp H aN aw ama ot wom, af ule wafeeal sera aedtat Vani m fay wher a feaarit wart gay discret wor ar anit g dl ga WHR aa Ta a waecal a aostat Varsit @ fer Gra wt waa wh F 10 vicar A ale wet erm | |
3. (®) Fe ape F wr-wged “wafecat” we at siftora & - feet ulster, wore, sea tena ofa o fax arise fireel Revered fret aerat
Mat srerat grasa war & fery feet sera at anf & fot tee, eeara; dae Vow H WaT sq aera warner eq sera atelfie, afr
TNTGEI3-o | |

Bo , |
Bo THE GAZETTE OF INDIA : EXTRAORDINARY (Par It—Sec. 3(ii)]
waa Istie aqua @ data Yau & fey wea & wr FT ara at ag fot .
A war ot srerafrai|
| (@) ga oes F weage “cartet Vail S fre whe” ve ar ators e
. - Feith Wat ara oritat er at we Vat S vodes lea wes wierart a.
. cede sera rR wea at Gat oe G wfwa A at ws fret Wh war al aaah &, Wey SA Se Har H aqese 14 cen 15 4 siewkat Basi w fers at wg seratrat wf vet & | . :
4. tramp 1 ak 2 & vada oe fea A ary we St ate wateedt 7
oo. dite wast @ far wre or feat wr, Wi ve whee wa wT
' Prartt a & oreo ger dfaerert wor 4, fir wafecal ar aacttet Garatt
. @ fay wha vaya eh & gel oy fa fod ent Rengs @ ae S GRR
| SM S slat Ta GAY weg A get we fara fart Asad wer & eats alsa a tat Pronfer ae & ven fra after sera waft & wer ¥ wafeea w aerhet Vaal B fre Ghy sa A ord & a dy ert dem sent ikea
— RIM & we ward wa a weg F 1 CS ame F senha aye 7 sera
Ayer 14H Sd ta Aa a aT aT
5. (&) we ftaent woe 8 wafeeai cen aadiat Vast & fag Gre
| aa Say gs aM oe, wa sad va wa of ait a | ait, wet wafecat a aattet Vasit & fay the sat wet ae alda Gi, aE ag feet
: Ufaarant wer or Faria sera ad, sa dfiaant wa 4 tar ay ert
Sanit @ fey ote sat ae at frtert feng ag a, ak Uh wafecat a detent taal @ fay whe oe writ wen sea Aad eA ent Feat at
| ord &, aa Uh wateeal ser satel Gait & fay ota ve wea 4 a ee art ret eri as wrdt tery aera fafgaa ws fea F |
CO fa) wel so-eore @) & siefa wafeent ae aattat tarsi oo, sera warner, offer ser wats 8 data & sera aadhet Gast aH
| fay ota feet ve dfeaert wes 4 frente tarsi S waa & a wafeeal

| (AT IVE 3(ii)] SRA BT UAT; AAT o. a“
| aera Tatas tara S fag Ge ow eee aor A aay EE art eh
«gs wet, rermat an ert cant @ Ae aert wa ahi ak ARI oer afer & rq fet fers wer a dda eh @ oro vafceal sea aaiet
' Want & fore ote wary, warner & ade 4 fora & fore ae sea at ard
| 2% fod ft or a va wk a afte sf ot 2 fra wee dal A
. srufeta 4 sereel cer feaart ari err wena et 7g ah, set ga ape
— wae See afta afta wear we ay eh | 8a ae 4 oerafral ar
— @ orp & atpa oad eT |
7 arpa - 13 OO |
' 1. ayee6 F vicar sik gay wftcront wea 4 fra stat wart }
+ SOT U yH afacrort wer @ feet Part arr ura afta w oa Guy |
Wey FEY TNA A Be |
2... hae woe @ sae S aM ae afters we ot uw face or
@ fodt sea ot ger dfacort wor 4 fea fedt weit dem at ona
| aafe a ge feen & sea fart Afeaa wr @ date Rh wa safe 3
aero Sora eM ae aftern oe wt dufe we daar wu & fer
Part ar gay dftaant wer F eia tafe Vast & waroref voce z, |
fea fet wa wri tem Get sera Ti sar & ae) sera Pfeaa .
wr & sera U ah aet afta Ht afta z Ta AR Tey oO TT
ae | .
3. sroersita aad 3 done UA ater Ga sta aga S sie B .
WI FAVOR S TAI, aga S oRercaa SV daila, ca waa H stay,
ERI wreat ata wx Saad wa dfecrant woe A ax oma wl waa, freer a fe sical Prardt & |

20 | THE GAZETTE OF INDIA : EXTRAORDINARY [Parr II—Src. i) , |
t: aaa=]k“evrew_w0*rtsSseeee ee ee ee eee eee eee eee eS eee j
: 4. fort oot 3 pit Kio S WR S sae S ore afte ® !

firret weafr F AVeTaa wedeta: serar sirereta: feet dfaeront wee W sraar | .
wate fra & Wee Wo 4 eX amar BET | .
- 5, fort oof, ot dacrent we» at Pant & w heme 4 4 ofeafta
B sera Ve H stereor Y wea aaah ae Ga Woy FH HT HMA TM Tara FI
: 6. my 1, 23,4 a5. 4 feats watt o hs fot a ah ae sero A ura aftanil ox der vel Uae we 8 ox ora wwe forran staworaat var Part & | a a OTEaE - 14 :
1. vo tilcert we & fet fart aa arn asi & freon
| Beal sh yer o Wea We at ar or-wonst Bo wa sa we aa oe wer Fa ATT UT aT, Tey Peafeftsa oR ot sisHr we Tet 3a
W gay Geant wor F at ae AIT a AST :
(@) ae veer aA arom & Pree @ yalorml, gar
. dcr wey 4 wa Afra wr Paha ws G soos z aT
. Oa AM FTA Ta Ver A hae Vat ara Wet SX TT HT
. wen vt oa Afsaa wr S aro equa gs AM oT wd 2; (a) afe gay Gfacert wor 4 vad cee wt safe a aati dafea fadta af F meq ee art aera ware ert ateit fot are Fa at gal A Ha fromx 183 fer sera Tee alae fet a, a oa amd Fora S Saag Bat SH AMT Ww VE GA
wa FOX ATT WI WaT, a va GY we F vas gu
. | Prone orel-awerdl G ured eg at |

| (9 fave 3(ii)) | See TATA; STETNTET a, | |
—————e—e=oaoaoaoaoooooaoaoaEaoaoaoauoaoaoaoaoaoaoaoaoao———————————————— CO ce
2. CarawiRres way” vz 4 ada tenes, wikia, wore, wee ae weafaftreret, <a fafecret ser carol 3 wads ardwery enfia & | .
Se | WTS - 15 —— 7
os 1 TBE 16, 18, 19, 20 she 21S aude S aia wd ey wa
Wien! wer @ fet Pat ae fet Pato & ddy A ura sari,
_ —- SagRat sik et vor & ora oR we daa alt wer FH ae aT, we
We fe Pater @ Freres gay ditererd woe A adi fear men at i ae te
— Prato fren war 8, dt at oa set S ora eet & Se Ta eRk TE
. 2 fhe 1 3 weet S aE, ww afta aor & fet Aart a
; . FRR wftarert wey 4 fey ay fat Rao & dda 4 ora ote oe Hae
Webfeed wer Fax cM oT wa, ae ape
. &) mernat, date fata ad F waa sera on ey feet ae
Har Ot Vet waft sera sraffal S fay que wow 4 ve ver
TH Gat Ponez 183 fet a aftr wai &,
| (@) inftafhas 88 fait rata are array gaat shy a arr fe
Ta &, Ul FAX ase aT Prat set @: sik (71) qitates tt fet ert dena sear At ert ER
| Teal el fra aren &, a Prato an Gay wor F et | .
3. TH qe } yfatt oudet & wage ww WRaant wer S AR ser
ERT aeReIy ararnat F eenferd feet cra sera agar ww fey ay Pro
. & dda A oreeg aRehe oy od wor F ae aA aT WaT | |
FIT Q@TN3-6 oe

- Be THE GAZETTE OF INDIA : EXTRAORDINARY [Parr Il—Sec. x1
oo SPOT - 16 | .
SO Rte at ate a -
. Peel at oe alk get ae at ore arate oe a ca dere tea S feet Pars are feet Sar, ol gay diearart wee ot Prarit & F
— Pein tsa & We ot stad 8 ot at ae el w va Gay wer FA oa vo ATT aT wae | | |
WT - 17 :
1 area 14 ate 15 & audi S arage A, ow WRaad wes Sh
| ard arr aor, a8 fe ag rex wafers, tea a gata woe seta feed witcane sera feet Racnst & wa 4 gay dfdarand wea F fay
Te Se rere & are tufsse ord-wonat S ort ara we Ga GE wet FH GX
| Ta UT War | | .
2. et fedt wikaawat sera feet faenst arr say ga war ao era
¥ fee ae tafgae ore-pont BS Wade A ore oa was AaRoreHal ar Raa wr wet wet &, oiftg fet ara aftr wr ura es, wht ara we aq 7, 14
| a 15 b Vid S Tage se dagen wu F ae ama a warm, few ritortaat erat Reena & art-perg fey at el
| 3. trom 1 ak 2 & vada feet ational aera fed fesenst ar, ger daant wes F Penfed or-wei 8 afer aa w ary ve et ale
. ger dftaert wor # fag mw org we at dal dfdant wat a wri sew a sas wria maeRa a adufia fifai err a wafsa ef | 8a are A wa ong we Gaa uel Ufaaert wma A ax wT
Runt de worl a Rar} Pant * | . .

; - | [1 Sve 3(i)) OI BI UITT ; SATE | a a
_ ae APOE - 18 | :
ae 19S te 2B oat S oad, va dered wer s |

fout fant at sae fied fat & sea d wr Ff oer ot ng tem alk 2
a vor S ara Rafe we dat et wer Hae ol WaT |
- 7 sige - 49 SO
|
“4. ) feeeit eifterert use srr sae fet wate o-wam sera |
| fer} writs ote arr fort af a se wer aera vo .
_ War sere wife & fore at mE Vast S dda F seq feu an
Ty tet & fet aaa, sagt aen set gor S ora ORafte wz |
ae Hae SH wor A St HM WT | CO oe a) weft, Ta das, ast ok eet TENS ora Rae Sa :
0 RRR afdarard wes 4 ait oe om wan, ae da we ee |
: at onl & sik aft ve wer ar ve arf a, ot:
| (i) Be wer ar ew ee & sera . |
Gi) Fa aa oe & sao Aa @ fay va wa a Part ,
SO wet ST Bt |
2. (#). ft Wtcert ao oer wed fet mode cose . |
. saat fert ware meer err sera ore err yer Paferat a
U fot aie a ve wea sea vom ae wees .
fey vam at as Vaal @ dda F aq at as fart tea we 4

Bae SH eT A ee oT TST | _

mo THE GAZETTE OF INDIA : EXTRAORDINARY [Paer Tt—Sec. 3] ' CO
oo ; (@) cena, Oat tert ue Sac ger dftarert wea Fae aT, ale to yO ate oa wey a art cen aiken et | | |
. . 3. Wye 15, 16, 17 HR 1s S wade, fot dlarrt weg aaa vas ; i fet wetter cram sera fat erie mae grr wore ae fat arian @ frette A wart wt as Wai S daar F aaa, Wot aie set ware
| Bara URE ser Fer Ww ary eT |
a | | STYeOe - 20
.. 2 . . 1c afk i f : / "
) 1. Hy WHA seas ma wMapal wl gay after} wy. A fore favafteraa, Herfdereta, flere srerat qax Wa F aI Aya urd CRI F
Rrermt ar whet ard a Sal S malo Sg VE Gey didaeont wg at Ga ae
SD eet od feet we Gftarerd aoe or frah & sera an, at waa Ta Gay
RR A TAS I aN St ata S al ad SG swale wi aah & fog WT
fret at ata ort & fou ora uefa we oa gay daca wey A ae
. Be ae et | . | J
2. sa ages 3 hore 1d wads Prafettea 4 ary ae eh
— @) Mar B are w ale Get ares cites A set far TT at
Urey Parse aida ser aferal & fact fea @ fore feear are
| @) sehr B awa A oer @ one we ae der seat a 7 sian & afifwres wre, 1960 H sitar sera Tas aR
oo | eta Mees went F fen wa es |
Oo 3. FA ages & geet fee fost wala a ferent eae ae are are WIE aie ae wa facia af A sera vas Get sect forte at wa wea F
| Prarit & firrt ge area eiftareore wer ar ahr Pe EI

[a 8g 36] , | Sea BL TTT: STAT _ | 25 | .
| ae AYRE - 21 a - | |
4, ag Rent or ae sRerent ae or de ad o ger .
Wiagront weal FS fx va or Pardt & sera en sik ot arr anett fan foo, ak wraght @ steal Ta ay wee 4 Weft sraraftral oe we we Enh, 4
(@) oe ora wor S ae & GS aaa arr Tas cre, eT j
Lo Ya wart & water @ fey oe fey wy TIT ae
. (za) uftafite, ut ae Ret Rater & oma ae & AR ax om |
a ! Ufacrort use F ava aff Pate Gad seaeit 8 weet BH
. - USTs er URahe se wisal F ot sas aed H rg .
, we at I eet & fry aHeiya st aera varia wa S stfaa F aeg fe | ‘
Wt erat A wry aise at swat Ren sie war @ sarod ga oe FH aM :
wy wey Sas weary armas ot fa S amar ve asi at sale a afte
. wel fren | . |
1. Ww Sfterent wor & fart frat wt sir at wt as weed a |
vay ent a, fr w sa aw & Galad sql 4 fear at fea ma &

Oda BH WI A Hwee ett | a | |
2. dene 1} wide, aqade 6 S tem 2 4 aerufeafta ora wea a |

a mead sg 8 FA ara wary vet em, ae Wit ava a oral wH
| a7 GL }3~7 . | — = |
_ | | '

Bi. THE GAZETTE OF INDIA : EXTRAORDINARY [Part If——Sec. 3(ti)]
Berard aor ar Pant ay S aed que wftarert wor A ae fer ART
| fet Aigaa wr 8 eda dafdce day Ponta oa @ den ten after great erafer formas tae FH Ue ora sar at ont & Ca weit dem sera
: fifead war B ward wa S wag F | OA ae 4 area 7 sre ages 14
. SS Brae, Ger At Aa al, ay a | 7
| og, tan 1 aad S A ee A aR Rt Wat we oI TE
wmita % os we vd fet vor & a Gel seat yan Ga sera feet
RE SY wee, Tt a, @ wa A ale S ora wet Oa F at ga ERG
Weal Sa we Gar Uisarandt Wor FB TMT VT PHT | .
, | . | - ; 93 s ot |
i a . , |
| Sek SET S sareHeoy wt Fay
1. aa 4 & Pet of dftaad wa §ouge ora oe aR a
BSE vata dares wai Fone S Saar a afenftr wa Wa, Teh
; 3a Hex F faata waar fy ae Bi | _ a
. 2. Sek ae oT aT Parga Pear aT
®) wet ana an Bs Pat Wh ara wear ara 2 Pe we ge aed :
wad G sg gr dita wa 4 ar wn WI wom & Te wreaked wea, se Pah a ama woe H vida AF wa GR ae F a fry my ox a eae UY oe Hell at agai yar ST | .
. | aenfa, wit well, we feu ort a cect serdar a H va wT a afte ae eit fire 4a se ara ot a, ter A aren 2, fore ae oe GEx
7 Usa FHP TMA VT WHat s |
(@) ae, sa oR @ fort A ody & agar fact & fad fra
| aR Wad Hl TS ary Ww Ga wor A HY G Be ora eld 8 det Gar aes fx H

_ [ORT tare 3(4i) J TRI BT UST; SAT nm 7 |
tet Part ot as ona wy ar ot crue wt WT S WA we wer onar wy |
— ae ewti - _ _
co WPT - 24 ae |
_ 14 We Wfarert wee S uel w ser daaaert wo 7 ta aig
| BRET oreray cede Cet wg orien any val at ore} Gl Ge wererg B alk
| acddet atensit 8 fr srerat after wept st, wl va guy wer & ufeat w -
_ fared: Fara & tide AF o-dt oRRa 4H ony eet et aera ary a on ward i tL SRI 1S Sada S ed gy Ah ae wade wa aafsaal oe A wry eT oh 7
_ Uh seat St ufacront wat & rari wet s | oo |
ae 2. ve dftcent wee o fit sem 3 aR daet we A fea ee. |
| TRI We Ta Fay Wer Fer ay Sey ary Tet fa TET U) wu gar
, UY GS Ta Wwe sigan a oe 9 ay eA Ta gwar B
7 +. Meatpd OF apa a | Fa soda at we aef act ama wen fe we
- —— Mfaerertt wou & fery we sterpx 8 fh ae gay fares aoe H Prafeai
By, owe water & fay saat fefte efraa aera wRaRe fistakal o
| fay faxt ver ot Wit afer ve wed set wdlfcal at Hot & at ae i
| army Prarkerdti ar car & | | |
; 3. Wa aa @I Viger Vet apeeg 9 G ame 1, ape 11S eo 7
| aq aped i2 6 hop 6 G way or ad BS Uae was fee
GIy ET Guy wfderart wor & feet Part of aa fed ag ena, wad,
, Wa G aI wekii-aegq ey APT saat pram seacahsr wou w foe 4
Pratt rarer fear rar et |
: 4. Ue Afagert wa od veri w frat dot cae Tae a - |
ayet wr sift wa S gay dfaarert war S vw a ale Parfeah # earfirca
Faw wre a Peifta ot ort a, werlfeaftsa wor Foy ta oe)
aM MTT MT Test HY wet sen ast aA wet a wa ana Balk aaa stent 8 1 sera afte ae & wt werfeaksd Wor B ay _
: 4

RG ATETTE OF INDIA EXTRAORDINARY Past Sec. 200) |
- Wars veri way Auten aypatoarts)
: 5 MA G Vad, So ARI RA eA A was sini amd & | —_
. ceo WTAE - 25
Fg, coet OY ofa ae wre & & ew oer eet aftr oat A
et A RN & sada G yw al St ae a Teal S weet eral ge sta.
_ PUY WT STA F ee gy At so AH Va Waar wea S was wert
ATO 24H RTH 1 H sera se F Tt as SHAT Ae Ga Widarant wey wera onferart wr mega we wan @ firs fe ag ufee & | gaa a
Be Gas Hl wert stray B dy asi @ tay savy eqd ay fea ar a@fey Bree cRoRe Ce SRI OTT TTF a ga EIR G Gadel S
HRA Tet F | |
+g af Gare aiRrart ar ana it oy sik ae ae ed eh do
Ba Ot Uday A opemef a, al ae WS Gae & GRex a sfe G a ga awe
@ ape 7a & Gar vfdarent wor S wer mito H wer meas eas
ERI SU AHet ol sa SM HT Ha He | ga oR fy ay fHyt awe wr
. Weare weal & west ort A fost ara dna o ee ey at fraaa fram | Lo
3. sa aR A aren ae gua any SS A aE Sardai- ser
7 were a, aA alaranrt asa GS was wert cs wRARG cena Seal HTT
. wT rane Sey | doa aralt 4 ft Sex Gaa al oe & fry wan fra fore ex wad & ferret ga Har A aan val Ht ag eI |
Lg tage dermal b sift t as wer wet S gato deren eee oe @ WAH wien wey GRY se we wd wader we vod & | aa frani >
die server 8g SIN or gu fe F er ales wa sta s al ga We

(aT ewe 3i)] A BT TATA + HAITI » a a =
@ Merwe wi daaat wet S car wheal B wfaeal aa cs |

RT @ Area S fear ot apa z | -
4, ier ero Swe met Ot ET Geet set wet :
St aftirnttra afte dita) ar oner-rer we wt fH ga aR S oad at 7
sere Sacro Weal sera SIs wath Tea arta wet mat at Ms

- ke RB wy TY ree ve Td ft S aa O daa aaa art + —.

- RAR GH Hfttgwet Felt F | GMAT or oneal srypewe 1 ae 2 ener wftafa ae |
a . | A

‘ 2... afreront wea ene terme 1 sini wet at ag ats qear va ae a (oS ataRe orp & siefa ora You BS AR S TS ah eh aie va 7:
| @aa wa eafaral sera oiffenftal (arenes sik wearer feos enfta 8 at 4
gee fer ore ot ears 1 4 ufeafaa aed 3 dda t a or Paka am 4
wat Well eA, Te wads sera afar & dda F sera ante a "
Rake oe a sage at qn a dag a 1 te afta am wert qa aT ; 7

BRT Sara WS é wah S fag eM 13 sa Yeon oF adults wees a . i erated sera ante Peat a re oe abt | ydadt trast F ee ey at -

we vitae wes a wear at ws Ye Ht Gay wari & fore watt fea - i

| wT Wa & wa Wet Ya SB at weal S or @ ged WG ara wan F oa, fery sary fea ore et ak angitadt wor ao was wiftert wa mar wr -
gst oft RR a deeme 4b wudet an anf feet where wer a So
17 Gils -& . | -

7

| id

30 . THE GAZETTE OF INDIA : EXTRAORDINARY | [Pant I-—Sec. 360)
gw) Ut geen (ret aeadat geet aertot Yt aiffrenfe wfoat oO
, . wiia 8) at wong Her at wa sera a flat ms a ort & siete serat are Gt waa feta A wrer Tee , a) Ut Gat at wong wen fred SE ora artery ailehfire, yee eft, Rr wae ae wadurie He @ wfapa er (arsx Uf) | | |
a za ogee B organ Fae Pe aaron wer gr Bet area |
_ ot arat aet & fore arquer farar ort & at gae witarert wor ate Ht 7
. aon wt ama oe d fay ant qa wear wel ae woah er grat
_ PMN, WS VS GAY Tor ot and ead F ax gated & fag Ot gaa at HE
| ora 7 et | fect aay 4 srahifed afta terare 3 at dita @ att
& firrg fot at Rafe a et dhnat at ae ori ae erm fH wiacarent wou
| oda safe Gan wang oe oan od 8 fe KH qe 7 sen wg staRe fea wet = |
; . |
5. feet wt feta A theme 3 3 wedi oof daa see GT
agit at SFT ae @ fery feet wfterant wey al arqafa ey oh fag wel ara wren PH yaa fat Je, ae te hens, et wk aw fat =A
” ema 4H oreRa Ad a afer G are & a ve feet alsa & varie fea 3
wats Ft seq - 27 | 7
| art Ht age F wera |
4 acre eer wore erat at age Aue get at wea ae
. — WENTT sree 1 aR 2 are oie set & | Asarat wes w very wise
BT HFRS H seyrArT Gt Fahey TI TEAls EI TI GY Wed z |
_ 2. ge orga 3 en wae we “ae cra" ar ment facet waa

or , 1 cet + 4 Soyer
- [aT UE 3(ii)] ORT ST WATT : TST ne
Ria VAS wore s-raPt aera write weal a sie Y we ag -
WH fer S a alk fra S dda 4 cy we Ye wei aw was sivia a
SRT Be ERR aera feet ser wren, ferred fey dfaarrd wow va FH
wearer Ot Uy @ deat ara, verahry api-ds alle aye a arrdt srera =
' Germ & vfsp aet z | a _
3. wa firt decree wer a We aa we wee Ss arp F site wartie dat & sik ae feet afea arr ea eta @ ait va aaa ve UG
art & sitts gaat aye Ht tee ae Mea ae sa Woe aa HI VA eI
- B WaH mart GS aaa Ww gay Maen wey @ aaa widfeRal err |
wee waroref eer fear ore | oe eR aa aH oa Te a a |
, wa & art H. vada afk agell, ay fos wore cra va Gay Wor SI WHS
cat et, & fay ier gas Gr S ordeal @ orga wa gar wacrent we
; ‘ {
+ 4 We fart dita we a Tera aa de aa ze fam tds F aE 7 |
ST, OM TPT G sits, guat aye a yaad ae a fag dam s - |
TW GWM F Ad FH WI ad Hl GVA Tor S wa wart S ama w |
| Gay Wace wer G weary Wort ae dem dS wa Het H waren
Wier oy fear aT | as AT We Va we ad GS Ma A at arp, ; art fe Word ad SH RAT WHT F Wo ard el, H Bide H arpa Tam w .
| Ba GT sel aw fe we We waa a wat fea wa & wees aa 7
a, mrifeaked wer f yada ad & aera oe cafes ant ea & ARI swat agit
Vat BT altro zs | ; : :
5. tue 3 aia & oudet & aa eg oft deo 3 geal 4 H pao |
fort dffarert wer grr wien fear wan aan ve wor F feet wa den &
sea wet ern sera oat wT A ea SUS wa S ORT va WI S orp =
& arta fowt word aa & wares Hrs weiter sel st org | gee arora, harp 3 sed 4 & sarees fet dfdarart wea gra wim fer ay wore
Water Hg wre AS Vr 1 |
, n

32 THE GAZETTE OF INDIA : EXTRAORDINARY [Part II—Sec. 3(ii)]
6. fori dtaaent was & word aa & aftaca, deer sera wh w dae
. i ora a daa se wer } ae sera erate Por S waa re
. SIG | FA spews F tar Ho sel & foraar oef que wfearort wor w fret
. wares sear perahre Prova & one Wh ardadt & fer fort after a
YO SMT HAT WET HET oA GATT | |
7. wet teers 3 oer 4 & aed feet efacrart woe arr ate fey or
@ usa feet ara sik wemtfeaftsa wor A weft word ad of RR
Uaat ws A aa wer aie Ha GA A sect Waller Wored aa ae
Preafettaa & ddr 4 ware et TET :
| o) tame 3 & siecle ada & armel 4, verhfectaa wor aT OIE
Ua ad GT sa we S orp S aed wathia z sik aff grr ta & ot oe aaa va wea & orp & sits gaat ash ten tal Wea ; STAT |
@ deme 4 o oats ota S ae 4, verifenttaa wor }
wae aa fired dar 4 ae wes ay orp & ded gaat age grad oe H wees S PAM H GI HAT é ; yoraieeattat wer wr wart went se aes aT GUY wor H wer wile GT
aco aftrafia ae stk gay wor & famed ae werifeead Wor a sre BT at at areata He a fe get eT |
8. se area } fret Wt aude or onl St Fa fore AM afacrant ae ux frafaftaa & fer aeaat aL SMT Fel TAT STG:
&) Be Wftaant wer sea gay dftaent wa G arp sik para ve S stra wera ST HET ;
@) | WA ora Het Th ate AA Gr afer) -& fata a; on) warrant vert @ear afe Gar Ufaarnnl wor A gAG GrPH sera

[1 HWE 3(ii)] ret ar TERRA: STRATEN . 3 -
I Taree wer we seria wore agel sera tem, sar a |
. | oo Tre a, & wit ayaa saat wr a fat si ;

a W) |. OA Amel F Gerad Wem OMT Get va wor & fae yaraha
So WS srqarasts at | |
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| aera ade O Udita sam west oral va sae H ouael al ary ae B .
co wel eet, aie a ga we A afore et sera wet |
7 2 we iar wa a a Ranft gw eae Ss anil o fy ee |
en, Fad Hat a su sar 3 aah fear wa en, amt fe gaat ya |
RS se A AS we qe ge oe S aitfa ari Ho .
BAT AT | | ;
3, fare aerat BOS ane, fora meni ortare waa we *
Ba sya S Badal A efter | .
| arpeeq - 29 |
. aorta faa & wees wd wig a2
ae TAN a fant aa a shrerta at S arr Pah Saints saa fate arnt & wadedl & stia worfie fre & waa aera aby aftankal & fata fasranftert w pig ware vet TSA | ‘
WT GTN -9 a |
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_ - — PBT- 300 -
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Bek ay argh BF | :
er) We ae a aed & hore 1 Ft eieefa agen a Ted , aha @ vga erm | so
- | 3. | qa wae} wade or AA waa eT | a
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_ ak
7 a w@) grit a, fre daer ad 4 xe ae ory der Boe oe gad dare af S yous we at are ata o) saa gad
| are aH VY aret fare faette ae HF wrear wt my arr B eae HI
a _ OrTpasE - 31
| | UU SRT A Ware ae we fear ora | Se AS ang wt efdcront wa ga a & ary eh a atta & aay cia at ot ofl FI eM & ae Ye OM
. ara fant daver aE at waa S aa SY wr os AEA ved wos aeaA a a Sars wr Aiea sax Hae BH ea BX weal & | Oeft fala 4 ae or AA
Maer F Arr B are : . |

. [A are 345) ] WS Bt UIT: SATA | . | 35
| wD oare 9 fore dew ad Fae ota Rar on ewe are aya Soret aE ot vech otter a sre wad ae
SO facta ag Fore at ag ona & wide F ; sik . | Se
7 a) eit dy fie dae af dwn wate Ao oe
, VAS Wie aad Hever a HS You We H aed fe S ae |
_ BIA Ban are fort at facta af A ona wt ag ara S tide A
| -_ fad wer 8, gad ferq Aaa wr Yo mRA arteeneRal a sa
RRR Ree fee F 1 _ .
SO adhe oar i ad a gore une org me Swe Ra RA
oe so ana 4 al-at Wer feat 4 Pers fear var sik wh ae wart we a |
= waftre | aet Frean 4 frearar at fafa 4 sitet we wardt are are |
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| ole TF Rasta sree) :
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@ fers ane Ter sik tela cteaiie were sRriftar st wen se dy aR W aie Fea GS @ fae aelecnadt Preafeksa sodai we wend By
Ewes rr ot a oo
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@ ware, 183 fest at safa wa arte 8 ye att & fore atta at Praia,
| fas ore area w fear we waa aw fea A A Aa i ogee anfe
; wl ung oer & fey, fag ay waa at At ga water aq Bis feat GTET | |

%6 THE GAZETTE OF INDIA : EXTRAORDINARY [Part II—Sec. 3(ii)]
2. wpe 24 (GA AER) H way 4 - ge wae one @ fH ga sqada wD
wadel or set aa @ ad 4 safes Hat & aral wl ax Ht va aw wR? Ge O Yea vet ern, ot wertfeaftsa dflaert wor H set ae at |
wart & arel wx ery ay wa oe O afte & a A ae qewea 7 (RANG
ay) & rary 3G sade H uftpa z | |
3. Ue Was wal & fo afe fot daent war a siaRe aAy su
RR G satel ot gon 4 que dfacent wa & feet Prat & fey afte amor @, at weriferftad wer am feet Pant & fey afie amet & a rerifcaktadt wor & sake ort se wha ae ony eft fora dh ge a va
Frardt a ferg aftr orraret & |

frad wer a sad fae faffaa wr O wilt setecmeaRal 4 ga wrareret OX BETTER fey = | , |
arta srarat 4 af at cor vane & ag are S veh fee eet we sith arsrait Fo e-et qa wfaat 4 Pre fear var sik wit ws WAM wT
grafts & | ref Preaer ay fretar ot Pera 4 sitet gro werdt ArT TGA |
ART TRY Ht deta atpaire WORT
GO St aie & sPratftar at HER Bt sie
Aki,
TH. PM) (gerard areata)
“aan va antics facore at

| eo on
[aM wre 3(ii)) ORT UAT: STATUTT | | 37 7
. MINISTRY OF FINANCE .
’ . (Department of Revenue) oy
| . NOTIFICATION ay
New Delhi, the 21st February, 2013 , a
| (INCOME TAX) oe . | Z
. . , los
§.0. 418(E).— Whereas the annexed Agreement between the Government of the Republic of |
India and the Government of the Federal Democratic Republic of Ethiopia for the Avoidance of |
Double Taxation and the Prevention of fiscal evasion with respect to taxes on income signed in {
- Addis Ababa on the 25" May, 2011 shall come into force on the 15" day of October, 2012, being |
. the date of later of the notifications after completion of the procedures as required by the
: respective laws for the entry into force of this Agreement, in accordance with Article 30 of the said
Agreement. |
‘ - 4
Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act, 4
1961 (43 of 1961), the Central Government hereby notifies that all the provisions of the said 3
Agreement annexed hereto shall be given effect to in the Union of India with effect from the he -
day of April, 2013. Oo a oS ee: 4
er ‘ 3
. ; oe x: 4
: . [Notification No. 14/2013-FT&TR-I/F. No. 503/01/1996-FT&TR-Il] jot
: | K. RAMALINGAM, Jt. Secy. |
OO | AGREEMENT _
a BETWEEN | |
THE GOVERNMENT OF THE REPUBLIC OF INDIA 7
a AND |
’ THE GOVERNMENT OF THE FEDERAL DEMOCRATIC REPUBLIC OF ETHIOPIA oe
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 Federal a
Democratic Republic of Ethiopia, desiring to conclude an Agreement for the
- avoidance of double taxation and the prevention of fiscal evasion with respect to :
taxes on income and with a view to promoting economic cooperation between the two countries, have agreed as follows:
TT GEUZ~10
. '
‘ j

3B THE GAZETTE OF INDIA : EXTRAORDINARY [Part I—Sec. 3¢i)] |
| —_ Article 1 en
PERSONS COVERED .
This Agreement shall apply to persons who are residents of one or both of the
Contracting States. . -
- _ Article 2
. le TAXES COVERED . i
1. This Agreement shall apply to taxes on income imposed on behalf of a
Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.
2. There shail be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of
_ Movable or immovable property and taxes on the total amounts of wages or salaries
' paid by enterprises.
3. The existing taxes to which this Agreement shail apply are in particular:
, ; Do a) in the case of India, the income tax, including any surcharge thereon; (hereinafter referred to as "Indian tax’); i
. ) in the case of Ethiopia :- .
7 (i) The tax on income and profit imposed by the Income Tax
Prociamation No.286/2002; and (ii) The tax on income from mining, petroleum and agricultural activities imposed by the respective Proclamations (hereinafter referred to as “ Ethiopian tax’). .

4. The Agreement shall apply also to any identical or substantially similar taxes, which are imposed after the date of signature of this Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes, which have been made in their respective taxation laws. | .

- Article 3
GENERAL DEFINITIONS
1. For the purposes of this Agreement, unless the context otherwise requires:
a) the term “India” means the territory of India and includes the
; territorial sea and airspace above it, as well as any other maritime zone in which India has sovereign rights, other rights and jurisdiction, according to the indian law and in accordance with international faw, including the U.N.
Convention on the Law of the Sea;

- i 4
| | _ a
_ (NT Tiare 341) ] ARG STATA: STATUTE ce) as b) the term “Ethiopia” means the Federal Democratic Republic of He,
Ethiopia, when used in a geographical sense, it means the national territory bo
' and any other area which in accordance with international law or the laws of =. «| 4
a Ethiopia is or may be designated as an area in which Ethiopia exercises sovereign rights or its jurisdiction; |
c) the terms a "Contracting State” and “the other Contracting State” mean F
the Republic of India or Federal Democratic Republic of Ethiopia as the |
context requires; os . ' |
. d) the term "person" includes an individual, a company, a body of persons | ; |
_and any other entity which is treated as a taxable unit under the taxation laws in |
force in the respective Contracting States; . f e) the term “company” means any ‘body corporate or any entity that is r treated as a body corporate for tax purposes; ; _ |
: , ‘ |
. fh} the term “ enterprise” applies to the carrying on of any business; | a
‘ - «g)_—s the terms-“enterprise of a Contracting State" and “enterprise of the other Contracting State" mean respectively an enterprise carried on by a , |
‘ resident of a Contracting State and an enterprise carried on by a resident of the _ ,
. _ other Contracting State, . ae , ni) the term “international traffic’ means any transport by a ship or aircraft operated by an enterprise of a Contracting State, except when the ship or aircraft is operated solely between places in the other Contracting State; i) the term “competent authority" means: . oe
- (i) in the case of India: the Finance Minister, Government of india, or -
. his authorized representative; a (ii) in the case of Ethiopia, the Minister of Finance and Economic
. Development or his authorized representative; .
' 9) the term "national" means: , (i) any individual possessing the nationality of a Contracting State; —
(ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State; k) the term “tax” means Indian or Ethiopian tax, as the context requires, but ‘
shall not include any amount which is payable in respect of any default or ; omission in relation to the taxes to which this Agreement applies or which .
represents a penalty or fine imposed relating to those taxes; ;
1, . . .

‘ ae , 1 3
4 | THE GAZETTE OF INDIA : EXTRAORDINARY [Pari [—Sec. 3fii)]
SSS SSS
i) The term “fiscal year’ means:
; i) in the case of India: the financial year beginning on the 1“ day of
. April; ; :
ii) in the case of Ethiopia: the year beginning on the 8” day of July.
2. As regards the application of the Agreement at any time by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the = .
meaning that it has at that time under the law of that State for the purposes of the taxes to which the Agreement applies and any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other laws of that State.
— — Artile4 .
RESIDENT
en For the purposes of this Agreement, the term "resident of a Contracting State" 7
means any person who, under the laws of that State, ts tiable to tax therein by reason of his domicile, residence, place of management, or any other criterion of a similar nature, and also includes that State and any political subdivision or local ; authority thereof. This term, however, does not include any person who is liable to:
tax in that State in respect only of income from sources in that State. ; .
2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shal! be determined as follows:
| a) he shall be deemed to be a resident only of the State in which he has a
_ pérmanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State oO with which his personal and economic relations are closer (centre of vita!
interests); b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either
State, he shall be deemed to be a resident only of the State in which he has
. an habitual abode;
| c) if he has an habitual abode in both States or in neither of them, he shail be deemed to be a resident only of the State of which he is a national; .
d) if he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
3. | Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a
. . | if!
}
i"

Cm lave 3(ii)] ART BT UAT : STANT 41
S ” tesident only of the State in which its place of effective management is situated. If , the State in which its place of effective management is situated cannot be determined, then the competent authorities of the Contracting States shall settle the question by mutual agreement. .
; ‘ Article 5 a
. a PERMANENT ESTABLISHMENT
1. For the purposes of this Agreement the term “permanent establishment" -
means a fixed place of business through which the business of an enterprise is whoily or partly carried on. ;
2. ‘The term “permanent establishment” includes especially:
a) a place of management; ’ |
* _b) a branch; .
- )} an office; .
djafactory; . .
no, e)aworkshop; . — - . :
‘ f) asales outlet; g) a warehouse in relation to a person providing storage facilities for others;
‘ h) a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried on; and ” 7
: - }) amine, an oil or gas well, a quarry or any other place of extraction of natural resources,
; wt , ;
3. (a) A building site or construction, installation or assembly project or supervisory activities in connection therewith constitutes a permanent establishment only if such
Site, project or activities last more than 183 days.
(b) The furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only if activities of that nature continue (for the same or a connected project)
within a Contracting State for a period or periods aggregating more than six months
_ within any twelve-month period. ‘
4. Notwithstanding the preceding provisions of this Article, the term “permanent
' eStablishment' shail be deemed not to include: :
a) the use of facilities solely for the purpose of storage or display of goods or merchandise belonging to the enterprise; oo -
b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage or display; |
TIT GTfizn-the = - .
. ;

po, . \. |
a ee THE GAZETTE OF INDIA : EXTRAORDINARY | [Part [1—Szc. 3(ii)] .
. c) the maintenance of a stock of goods or merchandise belonging to the
* a enterprise solely for the purpose of processing by another enterprise; _
7 ; d) the maintenance of a fixed place of business solely for the purpose of . -
purchasing goods or merchandise or of collecting information, for the
' . enterprise; ;
; e} the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise any other activity of a preparatory or auxiliary character, f} the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e} provided that the overall activity of the fixed place of business resulting from this combination
. is of a preparatory or auxiliary character.
5. _ Notwithstanding the provisions of paragraphs 1 and 2, where a person other
_ than an agent of an independent status to whom paragraph 7 applies is acting in a
Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned
Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person: : :
a) has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent _
establishment under the provisions of that paragraph; or b) has no such authority, but habitually maintains in the first-mentioned
State a stock of goods or merchandise from which he reguiarly delivers goods or merchandise on behalf of the enterprise; or
7 c) habitually secures orders in the first-mentioned State, wholly or almost
| wholly for the enterprise itself. 7
6. An enterprise shall not be deemed to have a permanent establishment in a
Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business.
However, when the activities of such an agent are devoted wholly or almost wholly
7 on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph.
\.

[RT fee 3(ii)] ART TTT: TETURTTT _ B |
| 7. The fact that a company which is a resident of a Contracting State controls or : |
is controlled by a company which is a resident of the other Contracting State or Ye which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent .
establishment of the other. - : = 7
SO Article 6 se
: INCOME FROM IMMOVABLE PROPERTY . ' mot
; .!
4. Income derived by a resident of a Contracting State from immovable property situated in the other Contracting State may be taxed in that other State.
2. The term “immovable property” shall have the meaning which it has under the |
law of the Contracting State in which the property in question is situated. The term sy shail in any case include property accessory to immovable property, livestock and ns equipment used in agriculture and forestry, rights to which the provisions of general
.law respecting landed property apply, usufruct of immovable property and rights to. |
variable or fixed payments as consideration for the working of, or the right to work, |
mineral deposits, sources and other natural resources; ships, boats and aircraft shall |
not be regarded as immovable property. . .
‘ 3. The provisions of paragraph 1 shall apply to income derived from the direct . :
, use, letting, or use in any other form of immovable property. . :
|
. 4. The provisions of paragraphs 1 and 3 shall also apply to the income from ; |
' immovable property of an enterprise and to income from immovable property used st for the performance of independent personal services. . te |
a . Article 7 | |
BUSINESS PROFITS 7
1. The profits of an enterprise of a Contracting State shall be taxable only in that ,
- State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on ; business as aforesaid, the profits of the enterprisé may be taxed in the other State but only so much of them as is attributable to that, permanent establishment.
2.- Subject to the provisions of paragraph 3, where an enterprise of a Contracting
State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it ; were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.

so - . ; a ; - . _ I"
aA . THE GAZETTE OF INDIA : EXTRAORDINARY [Part II—Sec. 3(ii)]
aoooaoooooooooooeESESEESESEooEooomeaq«aaeaanaouauauauauouuu0unuQqQqqqmm SSS >
3. .In determining the profits of a permanent establishment, there shall be
‘allowed as deductions expenses which are incurred for the purposes of the
_ permanent establishment, including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or __,
- elsewhere, in accordance with the provisions of and subject to the limitations of the tax laws of that State. However, no such deduction shail be allowed in respect of ;
- ' amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by *
the permanent establishment to the head office of the enterprise or any of its other
_ Offices, by way of royalties, fees or other similar payments in return for the use of patents, know-how or other rights, or by way of commission or other charges for specific services performed or for management, or, except in the case of banking enterprises, by way of interest on moneys lent to the permanent establishment. _
Likewise, no account shall be taken, in the determination of the profits of a permanent establishment, for amounts charged (otherwise than toward reimbursement of actual expenses), by the permanent establishment to the head
-. - Office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents, know-how or other rights, or by way
. of commission or other charges for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on’moneys lent to.
the head office of the enterprise or any of its other offices.
4. insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be
- taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the -
principles contained in this Article.
5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.
6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.
7. Where profits include items of income which are dealt with separately in other
‘Articles of this Agreement then the provisions of those Articles shall not be affected
. . by the provisions of this Articte. , .

[ WT Was 3¢ii)) ¢ UW Bl WTF > SAUNT . 4S |
- Asticle 8
é . | SHIPPING AND AIR TRANSPORT . _
1. Profits derived by an enterprise of a Contracting State from the operation of
; ships or aircraft in international traffic shall be taxable only in that State.
| 2. Ifthe place of effective management of a shipping enterprise is aboard a ship, |
then it shall be deemed to be situated in the Contracting State in which the home harbor of the ship is situated, or, if there is no such home harbor, in the Contracting ;
State of which the operator of the ship is a resident.
3. For the purposes of this Article profits from the operation of ships or aircraft in intemational traffic shall include profits from the use, maintenance or rental of SO
containers (including trailers and related equipment for the transport of containers) ; :
used for the transport of goods or merchandise, where such use, maintenance or
. rental, as the case may be, is supplementary or incidental to the operation of ships :
or aircraft in international traffic. :
4. For the purposes of this Article interest on investments directly connected with the operation of ships or aircraft in international traffic shall be regarded as profits derived from the operation of such ships or aircraft if they are integral to the carrying .
on of such business, and the provisions of Article 11 shall not apply in relation to such interest. "
5. The provisions of paragraph 1 shall also apply to profits from the participation in a pool, a joint business or an international operating agency. mn
— 6. It is understood that the provisions of this Article shall replace the ‘provisions
. Of the Agreement between the Government of the Republic of India and the
Provincial Military Government of Socialist Ethiopia for the Avoidance of Double oe
Taxation of Income of Enterprises Operating Aircraft signed on November, 25, 1976.
Article 9 ‘
ASSOCIATED ENTERPRISES
. 1. Where : , ' .
a) an enterprise of a Contracting State participates directly or indirectly in
\ the management, control or capital of an enterprise of the other Contracting
: State; or b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, sO ;
TT GEN3~12, :
; , i.

46 THE GAZETTE OF INDIA : EXTRAORDINARY [Part II—Sec. 3(ii)]
| and in either case conditions are made or imposed between the two enterprises ‘
in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for
; those conditions, have accrued to one of the enterprises, but, by reason of
. , those conditions, have not so accrued, may ‘be included in the profits of that
. enterprise and taxed accordingly. :
2. Where a Contracting State includes in the profits of an enterprise of that State
- and taxes accordingly - profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits -
; . which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have
- been made between independent enterprises, then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provisions of this
Agreement and the competent authorities of the Contracting States shall if necessary , consult each other. :
Article 10 ; mo DIVIDENDS
1. Dividends paid by a company which is a resident of a Contracting State toa
. resident of the other Contracting State may be taxed in that other State.
s ; i .
2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that
State, but if the beneficial owner of the dividends is a resident of the other
Contracting State, the tax so charged shall not exceed 7.5 per cent of the gross amount of the dividends. This paragraph shall not affect the taxation of the company in respect of the profits out of which the dividends are paid.
3. The term “dividends" as used in this Article means income from shares or other rights, not being debt-claims, participating in profits, as well as income from j other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident.
4. The provisions of paragraphs 1 and 2 shail not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the
. other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as
_ the case may be, shall apply. °
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i
’ [OFT L—-@re 3(i7)] t A Al USA: STATIN 47
a ' 5. Where a company which Is a resident of a Contracting State derives profits or
- " income from the other Contracting State, that other State may not impose any tax on - 0
the dividends paid by the company, except insofar as such dividends are paid to a
; resident of that other State or insofar as the hoiding in respect of which the dividends '
. are paid is effectively connected with a permanent establishment or a fixed base situated in that other State, nor subject the company’s undistributed profits to a tax on the company’s undistributed profits, even if the dividends paid or the undistributed ; profits consist wholly or partly of profits or income arising in such other State.
; Article 11 . , ;
INTEREST ;
4, Interest arising in a Contracting State and paid to a resident of the other
Contracting State may be taxed in that other State. . ,
2. However, such interest may also be taxed in the Contracting State in which it arises, and according to the laws of that State, but if the beneficial owner of the _
interest is a resident of the other Contracting State, the tax so charged shall not .
exceed 10 per cent of the gross amount of the interest.
3. Notwithstanding the provisions of paragraph 2, interest arising in a
Contracting State shall be exempt from tax in that State, provided that it is derived and beneficially owned by:
, a) the Government, a political sub-division or a local authority of the other Contracting State; or b) {i) in the case of India, the Reserve Bank of India; and
. {ii) in the case of Ethiopia, the National Bank of Ethiopia; or an) any other institution as may be agreed upon from time to time between the Competent authorities of the Contracting States through exchange of letters. ; :
4. The term "interest" as used in this Article means income from debt claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. Penalty charges for tate payment shall not be regarded as interest for the purpose of this Article.
5. The provisions of paragraphs 1 and 2 shall not apply if the beneficial owner of
, the interest, being a resident of a Contracting State, carries on business in the other
Contracting State in which the interest arises, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the debt claim in respect of which the interest is

48 THE GAZETTE OF INDIA : EXTRAORDINARY {Part II—Ssc. 3(ii)]
° paid is effectively connected with such permanent establishment or fixed base. tn .
' such case the provisions of Article 7 or Article 14, as the case may be, shall apply.
| 6. Interest shall be deemed to arise in a Contracting State when the payer is a
_ tesident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent —
establishment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment or fixed base, then such interest shall be deemed to arise in the State in which the permanent establishment or fixed base is situated. ,

. #, Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the interest, having regard to the debt -claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the —
absence of such relationship, the provisions of this Article shall apply only to the last mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the

. . Other provisions of this Agreement.

| | Article 12 | :

ROYALTIES AND FEES FOR TECHNICAL SERVICES
: ; i .
1. Royalties or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.
2. However, such royalties or fees for technical services may also be taxed in the Contracting State in which they arise, and according to the jaws of that State, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 per cent of the

gross amount of the royalties or fees for technical services.
3. (a) The term “royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of !
literary, artistic or scientific work including cinematdgraph films or films or tapes used for television or radio broadcasting, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, -
commercial or scientific experience.

(b) The term “fees for technical services” as used in this Article means payments of any kind, other than those mentioned in Articles 14 and 15 of this
Agreement as consideration for managerial or technical or consultancy services, including the provision of services of technical or other personnel.

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[At Gee 3(ii)] A ST USA; TAM o | a
4. The provisions of paragraph 1 and 2 shall not apply if the beneficial owner of the royalties or fees for technical services being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties or fees for technical services arise, through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base .
situated therein, and the right or property in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. ;
5. (a) Royalties and fees for technical services shall be deemed to arise in.a |
Contracting State when the payer is a resident of that State. Where, however, the person paying the royalties or fees for technical services, whether he is a resident of .
a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the liability to pay the royalties or fees for technical services was incurred, and such royalties or fees for technical services are borne by such permanent establishment or fixed base, then such royalties or fees for technical services shall be deemed to arise in the Contracting State in which the
* permanent establishment or fixed base is situated.
4 .
° (b) Where under sub-paragraph (a) royalties or fees for technical services do
. hot arise in one of the Contracting States, and the royalties relate to the use of, or the right to use, the right or property, or the fees for technical services relate to
. services performed, in one of the Contracting States, the royalties or fees for
. ‘ technical services shail be deemed to arise in that Contracting State.
6. Where, by reason of a special relationship between the payer and the beneficial owner or between both of them and some other person, the amount of the royalties or fees for technical services, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by ’
the payer and the beneficial owner in the absence of such relationship, the
‘provisions of this Article shall apply only to the jast-mentioned amount. !n such case, the excess part of the payments shall remain taxable according to the laws of each
Contracting State, due regard being had to the other provisions of this Agreement.
Article 13 7 ;
; CAPITAL GAINS ~*~
1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting ,
, State may be taxed in that other State.
2. Gains from the alienation of movable property forming part of the business property of a permanent establishment, which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base .
717 GENI tS _
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50 THE GAZETTE OF INDIA : EXTRAORDINARY [Part l—Sec. 3(ii)} |
| available to a resident of a Contracting State in the other Contracting State for the ; purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or , bo of such fixed base, may be taxed in that other State.
: 3. Gains from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships ar aircraft shall be taxable.
im . only in the Contracting State, of which the alienator is a resident.
4. Gains from the alienation of shares of the capital stock of a company the property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that State.
5. Gains from the alienation of shares other than those mentioned in paragraph
4 in a company which is a resident of a Contracting State may be taxed in that State.
8 B, Gains from the alienation of any property other than that referred to in :
paragraphs 1, 2, 3, 4 and 5, shall be taxable only in the Contracting State of which
. the alienator is a resident. | 4
Article 14
. INDEPENDENT PERSONAL SERVICES
4. Income derived by an individual who is a resident of a Contracting State from the performance of professional services or other independent activities of a similar character shail be taxable only in that State except in the following circumstances when such income may also be taxed in the other Contracting State.
a} if he has a fixed base regularly available to him in the other Contracting
State for the purpose of performing his activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other State;
, or |
~ b) if his stay in the other Contracting State is for a period or periods |
amounting to or exceeding in the aggregate 183 days in any period of 12 -
months period commencing or ending in the fiscal year concerned; in that case, only so much of the income as is derived from his activities performed in that other State may be taxed in that other State.
2. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent
- activities of physicians, fawyers, engineers, architects, surgeons, dentists and
. accountants.

[3 Tare 3(ii)) , ARG By USAT: SAT 51 a
Article 15
DEPENDENT PERSONAL SERVICES
1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages :
and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment a is exercised in the other Contracting State. If the employment is so exercised, such '
remuneration as is derived therefrom may be taxed in that other State. . |
| 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other |
Contracting State shall be taxable only in the first-mentioned State if: : |
a) the recipient is present in the other State for a period or periods not |
exceeding in the aggregate 183 days in any twelve month period commencing |
or ending in the fiscal year concerned; and |
b) the remuneration is paid by, or on behalf of, an employer who is not a
~ resident of the other State; and c) the remuneration is not borne by a permanent establishment or a fixed
. base which the employer has in the other State. .
3. Notwithstanding the preceding provisions of this Article, remuneration derived in
‘respect of an employment exercised aboard a ship or aircraft operated in
___ international traffic, by an enterprise of a Contracting State may be taxed in that ;
' State. - : oo.
: Article 16 oo
| . . DIRECTORS' FEES
Directors’ fees and other similar payments derived by a resident of a a
Contracting State in his capacity as a member of the board of directors in a company
_ which is a resident of the other Contracting State may be taxed in that other State.
Article +70” a
ARTISTES AND SPORTSPERSONS .
1. Notwithstanding the provisions of Articles 14 and 15, income derived by a
_ fesident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson from his personal activities as such exercised in the other Contracting State, may be taxed in that other yo
State.
2. Where income in respect of personal activities exercised by an entertainer or ; a sportsperson in his capacity as such accrues not to the entertainer or sportsperson himself but to another person, that income may, notwithstanding the provisions of _
; .

$2 THE GAZETTE OF INDIA : EXTRAORDINARY [Part lI—Sec. 3¢ii)) - |
‘Articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsperson are exercised.
3. ~ The provisions of paragraphs 1 and 2, shall not apply to income from activities :
- performed in a Contracting State by entertainers or sportspersons if the activities are substantially supported by public funds of one or both of the Contracting States or of .
- , political subdivisions or focal authorities thereof. In such a case, the income shall be ; ; taxable only in the Contracting State of which the entertainer or sportsperson is a :
resident. ;
. Article 18
aa PENSIONS | .
Subject to the provisions of paragraph 2 of Article 19, pensions, and other similar remuneration paid to a resident of a Contracting State in consideration of past
-. - employment shalt be taxable only in that State. 7
; | | Article 19
GOVERNMENT SERVICE » 4 .
- 4. a) Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an
- individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. ; b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the.
individual is a resident of that State who:
(i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the services.

2. a) Any pension paid by, or out of funds created by, a Contracting State ora political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. ;

b) However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.
rs 3. The provisions of Articles 15, 16, 17 and 18 shall appfy to salaries, wages and other similar remuneration, and to pensions, in respect of services rendered in connection with a business carried on by a Contracting State or a political oe subdivision or a local authority thereof.

[APT Hees 3¢ii)] : GRA A TATA : STATI _ 3 :
Article 20 an
. PROFESSORS, TEACHERS AND RESEARCH SCHOLARS
a A professor, teacher or research scholar who is or was a resident of the
Contracting State immediately before visiting the other Contracting State for the :
purpose of teaching or engaging in research, or both, at a university, college, school i or other similar approved institution, in that other Contracting State, shall be exempt [
from tax in that other State on any remuneration for such teaching or research fora |
period not exceeding two years from the date of his first arrival in that other |
Contracting State.
. - a |
2. The provisions of paragraph 1 of this Article shal not apply: : !
. (a) to income from research if such research is undertaken not in the |
public interest but for the private benefit of a specific person or persons; .
(b) in the case of Ethiopia, to income from teaching if such teaching is |
‘undertaken in an educational institution established under or in accordance ;
_ with the Commercial Code of Ethiopia, 1960.
’ 3. For the purposes of this Article, an individual shall be deemed to be a resident of
« a Contracting State if he-is resident in that State in the fiscal year in which he visits
"the other Contracting State or in the immediately preceding fiscal year.
8 Article 21 7 , a STUDENTS . oe
1, A student who is or was a resident of one of the Contracting States ~
immediately before visiting the other Contracting State and who is present in that —
other Contracting State solely for the purpose of his education or training, shall .
besides grants, loans and scholarships be exempt from tax in that other State on:
' a) payments made to him by persons residing outside that other State for the purposes of his maintenance, education or trainmg; and b) remuneration which he derives from an employment which he exercises in the other Contracting State if the employment is directly related to his studies and the remuneration constitutes earnings necessary for his maintenance.
2. The benefits of this Article shall extend only for such period of time as may be . , reasonabie or customarily required to complete the education or training undertaken, but in no event shall any individual have the benefits of this Article, for more than six
' consecutive years from the date of his first arrival for the purpose of his education or .
training in that other State.
987 GEN3-14 :
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4 THE GAZETTE OF INDIA : EXTRAORDINARY {Part Ii—Sec. 3(ii)}
. Article 22 7
. OTHER INCOME
> 1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that : .
~ ' State.
’ 2. ‘The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or
- performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is
_ @ffectively connected with such permanent establishment or fixed base. In such case -
*. + the provisions of Article 7 or Article 14, as the case may be, shall apply. .

. 3, Notwithstanding the provisions of paragraph 1, if a resident of a Contracting
State derives income from sources within the other Contracting State in’ form of lotteries, crossword puzzies, races including horse races, card games. and other _
games of any sort-or gambling or betting of any nature whatsoever, such income may be taxed in the other Contracting State. .

Asticle 23
METHODS FOR ELIMINATION OF DOUBLE TAXATION ;
1. The laws in force in either of the Contracting States will continue to govern the taxation of income in the respective Contracting States except where provisions to
. the contrary are made in this Agreement.
3. Double taxation shall be eliminated as follows:
(a) Where a resident of a Contracting State derives income which, in accordance with the provisions of this Agreement may be taxed in the other
Contracting State, the first-mentioned State shall allow as a deduction from the tax onthe income of that resident, an amount equal to the tax paid in that other State.
Such deduction shall not, however, exceed that part of the income tax as a computed before the deduction is given, which is attributable, as the case may be, to the income which may be taxed in that other State.
oo (b) Where in accordance with any provision of the Agreement, income derived by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income of such
' resident, take into account the exempted income. :

: “|
[SFT ees 3(ii)] SRE BT UAT; HATA 55 :
Article 24 7
. NON-DISCRIMINATION . ‘
1. Nationals of a Contracting State shall not be subjected in the other
Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which SO
nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the
' * provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States. uo
2. The taxation on a permanent establishment which an enterprise of a
Contracting State has in the other Contracting State shall not be less favorably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a
* . Contracting State to grant to residents of the other Contracting State any personal
Fs allowances, reliefs and reductions for taxation purposes on account of civil status or
: family responsibilities which it granis to its own residents. ;
3. Except where the provisions of paragraph 1 of Article 9, paragraph 7 of Article

- 11; or paragraph 6 of Article 12, apply, interest, royalties and other disbursements

- paid by an enterprise of a Contracting State to a resident of the other Contracting
State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the

first-mentioned State.
4. Enterprises of a Contracting State, the capital of which ts wholly or partly ; owned or controlled, directly or indirectly, by one or more residents of the other
' Contracting State, shall not be subjected in the first-mentioned Contracting State to .

- any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected.

5. The provisions of this Article shall apply only to taxes which are covered by this Agreement.
Article 25 . ,
MUTUAL AGREEMENT PROCEDURE os
1. Where a person considers that the actions of one or both of the Contracting ee .
States result or will result for him in taxation not in accordance with the provisions of this Agreement , he may, irrespective of the remedies provided by the domestic law of those the Contracting States, present his case to the competent authority of the |
4

56 THE GAZETTE OF INDIA : EXTRAORDINARY [Parr li—Ssc. 3(i)]
Contracting State of which he is a resident or, if his case comes under paragraph 1 |
"of Article 24, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting
; in taxation not in accordance with the provisions of the Agreement. a
2. The competent authority shall endeavour, if the objection appears to if to be __
. justified and if it is not itself able to arrive at a satisfactory solution, to resolve the ©
- case by mutual agreement with the competent authority of the other Contracting
State, with a view to the avoidance of taxation which is not in accordance. with the
Agreement. Any agreement reached shall be implemented not withstanding any
._ time limits in the domestic laws of the Contracting States.
3. The competent authorities of the Contracting States shall endeavour to .
~ Tesolve by mutual agreement any difficulties or doubts arising as to the interpretation
_ Or application of the Agreement. They may also consult together for the elimination
‘. Of double taxation in cases not provided for in the Agreement. ; .
. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement, in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission — -
consisting of representatives of the competent authorities of the Contracting States.
. Article 26
a EXCHANGE OF INFORMATION
1. The competent authorities of the Contracting States shalt exchange such information (including documents or certified copies of the documents) as is necessary for carrying out the provisions of this Agreement or of the domestic laws
.. concerning taxes of every kind and description imposed on behalf of the Contracting
States, or of their political subdivisions or local authorities insofar as the taxation thereunder is not contrary to the Agreement. The exchange of information is not restricted by Articles 1 and 2.
2. Any information received under paragraph 1 by a Contracting State shal/ be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in
~ relation to, the taxes referred to in paragraph 1, or the oversight of the above. Such
"persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions.
sO Notwithstanding the foregoing, information received by a Contracting State may be
; used for other purposes when such information may be used for such other

- [MMT [aE 3(ii)] SR ST UST: SFRTENTTT oT _ |
purposes under the laws of both States and the competent authority of the supplying .
State authorises such use. 7 CO
. 3. In no case shall the provisions of paragraph 1 be construed so as to impose on a .
Contracting State the obligation:
_ a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; , b) to supply information (including documents or certified copies of the |
documents) which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State;
‘¢) to supply information which would disclose any trade, business, industrial, . |
commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
4. If information is requested by a Contracting State in accordance with this ,
Article, the other Contracting State shall use its information gathering measures to
* . obtain the requested information, even though that other State may not need such
* information for its own. tax purposes. The obligation contained in the preceding
, sentence is subject to the limitations of paragraph 3 but in no case shall such
: limitations be construed to permit a Contracting State to decline to supply information solely because it has no domestic interest in such information. .
- &, In no case shall the provisions of paragraph 3 be construed to permit a -
Contracting State to decline to supply information solely because the information is - :
held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person.
| Article 27 a OO |
ASSISTANCE IN THE COLLECTION OF TAXES ; i
1. The Contracting States shall lend assistance to each other in the collection oo of revenue claims. This assistance is not restricted by Articles 1 and 2. The competent authorities of the Contracting States may by mutual agreement settle the mode of application of this Article. .
2. The term "revenue claim" as used in this Article means an amount owed in respect of taxes of every kind and description imposed on behalf of the Contracting ,
States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not contrary to this Agreement or any other instrument to which the
Contracting States are parties, as well as interest, administrative penalties and costs 7
of collection or conservancy related to such amount. _ .
PAIGE ft 77 |
$ . «

58 THE GAZETTE OF INDIA : EXTRAORDINARY [Parr Il—Sec. 3(ii)]

3. When a revenue claim of a Contracting State is enforceable under the laws of

| that State and is owed by a person who, at that time, cannot, under the laws of that
State, prevent its collection, that revenue claim shall, at the request of the competent authority of that State, be accepted for purposes of collection by the competent , authority of the other Contracting State. That revenue claim shall be collected by that other State in accordance with the provisions of its laws applicable to the enforcement and collection of its own taxes as if the revenue claim were a revenue
. claim of that other State.
. 4. ‘ When a revenue claim of a Contracting State is a claim in respect of which that State may, under its law, take measures of-conservancy with a view to ensure its collection, that revenue claim shall, at the request of the competent authority of that State, be accepted for purposes of taking measures of conservancy by the competent authority of the other Contracting State. That other State shall take measures of conservancy in respect of that revenue claim in accordance with the
_ provisions of its laws as if the revenue claim were a revenue claim of that other State
. even if, at the time when such measures are applied, the revenue claim is not .
enforceable in the first-mentioned State or is owed by a person who has a right to
‘ prevent its collection.
= 3 °

5. Notwithstanding the provisions of paragraphs 3 and 4, a revenue claim

accepted by a Contracting State for purposes of paragraph 3 or 4 shall not, in that

State, be subject to the time limits or accorded any priority applicable to a revenue

claim under the laws of that State by reason of its nature as such. In addition, a

revenue claim accepted by a Contracting State for the purposes of paragraph 3 or 4

shall not, in that State, have any priority applicable to that revenue claim under the

laws of the other Contracting State.

6. Proceedings with respect to the existence, validity or the amount of a revenue

claim of a Contracting State shall only be brought before the courts or administrative

bodies of that State. Nothing in this Article shall be construed as creating or providing any right to such proceedings before any court or administrative body of the other Contracting State.

7. Where, at any time after a request has been made by a Contracting State under paragraph 3 or 4 and before the other Contracting State has collected and remitted the relevant revenue claim to the first-mentioned State, the relevant revenue claim ceases to be

a) >in the case of a request under paragraph 3, a revenue claim of the first-
mentioned State that is enforceable under the laws of that State and is owed by a person who, at that time, cannot, under the laws of that State, prevent its
~ collection; or .
| ‘
|

t
[at Tae 3(ii)] TRG BI UIA : SATA 50 tows
) in the case of a request under paragraph 4, a revenue claim of the first- |
| mentioned State in respect of which that State may, under its laws, take . , measures of conservancy with a view to ensure its collection .
the competent authority of the first-mentioned State shall promptly notify the SG
competent authority of the other State of that fact and, at the option of the other :
_ State, the first-mentioned State shall either suspend or withdraw its request.
8. In no case shall the provisions of this Article be construed so as to impose on . |
a Contracting State the obligation:
a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State; ‘ |
b) to carry out measures which would be contrary to public policy (ordre |
public); ,
, a) to provide assistance if the other Contracting State has not pursued all reasonable measures of collection or conservancy, as the case may be,
~ available under its laws or administrative practice; . ot i d) to provide assistance in those cases where the administrative burden
: for that State is clearly disproportionate to the benefit to be derived by the other
Contracting State. -
mo Article 28 7 |
LIMITATION OF BENEFITS “
1. The provisions of this Agreement shall in no case prevent a Contracting State |
from the application of the provisions of its domestic law and measures concering tax avoidance or evasion, whether or not described as such.
' 2. A resident of a Contracting State shall not be entitled to the benefits of this
Agreement if its affairs were arranged in such a mamner as if it was the main purpose or one of the main purposes to take the benefits of this Agreement.
3. The case of legal entities not having bonafide business activities shall be
’ _ govered by the provisions of this Article.
Article 29
MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS .
Nothing in this Agreement shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or |
under the provisions of special agreements. |
: . ‘ op |
| 717 GT}is—-}e oo | |
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& THE GAZETTE OF INDIA : EXTRAORDINARY (Part [l—Sec. 3¢ii)] a
Article 30
ENTRY INTO FORCE
7 ;
1... The Contracting States shall notify each other in writing, through diplomatic -
channels, of the completion of the procedures required by the respective laws for the entry into force of this Agreement. . ;
2. This Agreement shall enter into force on the date of the later of the
. notifications referred to in paragraph 1 of this Article.
3. * The provisions of this Agreement shall have effect: .
(a) In India, in respect of income derived in any fiscal year beginning on or after
- the 1* of April next following the calendar year in which the Agreement enters oo, into force; and .
(b) In Ethiopia, in respect of income derived in any fiscal year beginning on or after the 8" day of July next follawing the calendar year in which the Agreement enters into force. _ pot
Article 31 . i
. TERMINATION
This Agreement shal! remain in force indefinitely until terminated by a
Contracting State. Either Contracting State may terminate the Agreement, through diplomatic channels, by giving notice of termination at least six months before the end of any calendar year beginning after the expiration of five years from the date of entry into force of the Agreement. In such event, the Agreement shall cease to have effect: :
a} In India, in respect of income derived in any fiscal year on or after the 1*' of
April next following the calendar year in which the notice is given; and b) In Ethiopia, in respect of income derived in any fiscal year on or after the 8"
of July next following the calendar year in which the notice is given;
IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this
Agreement. |
DONE in duplicate at Addis Ababa this 25" day of May, 2011, each in the Hindi and
English languages, both texts being equally authentic. In case of divergence of interpretation, the English text shall prevail.
For the Government of the For the Federal Democratic -
Republic of india: ; Republic of Ethiopia:
(S. M. KRISHNA) (SUFIAN AHMED)
External Affairs Minister Ministgr for Finance and Economic
Development

(9m ae 3(ii)] AR TSA: STATI 61
. PROTOCOL
- At the moment of signing the Agreement this day concluded between the |
Government of the Republic of India and the Government of the Federal Dernocratic
_ Republic of Ethiopia for the Avoidance of Double Taxation and the Prevention of
Fiscal Evasion with respect to Taxes on Income, the undersigned have agreed upon |
the following provisions which shail be an integral part of the Agreement. : a
1. For the purpose of computing the time limit in paragraph 3 (a) of Article
5(Permanent Establishment), the 183 days period begins as of the date on which the construction, installation or assembly project or supervisory activity itself begins; it -
does not take into account the time spent solely on preparatory activities. The time taken for obtaining licenses etc., shall also be excluded for this purpose. :

2. With respect to Article 24(Non-discrimination):- it is understood that the

provisions of this Article shall not be construed as preventing India from charging the |
profits of a permanent establishment of an Ethiopian company in India at a rate of |
tax which is higher than that imposed on the profits of a similar company of the first |

; mentioned Contracting State, nor as being in conflict with the provisions of
- paragraph 3 of Articile-7(Business Profits). !
3. It is understood that if the domestic law of a Contracting State is more _ |
* beneficial to a resident of the other Contracting State than the provisions of this
_ Agreement, then the provisions of the domestic law of the first-mentioned State shall
‘apply to the extent they are more beneficial to such a resident.

- IN WITNESS WHEREOF the undersigned, duly authorized thereto, have |
signed this Protocol. . |
DONE in duplicate at Addis Ababa this 25" day of May, 2011, each in the Hindi and
English languages, both texts being equally authentic. In case of divergence of ;

_ interpretation, the English text shall prevail. |
For the Government of the ° For the Federal Democratic _
Republic of India: * . Republic of Ethiopia: !

Keddie (We (S. M. KRISHNA) (SUELAN AHMED) | |
External Affairs Minister ‘ Minists for Finance and Economic ‘ oo
| Devel pment .

and Published by the Controller of Publications, Delhi-1 10054. . ; .

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