Notification: 53 Date of Issue: 5/7/2013

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Tat Fo Slo Weto-33004/99 REGD. NO. D. L.-33004/99
reas eee Ca =
Che Gazette of India
HATA
EXTRAORDINARY
um []—avg 3—3u-ave (ii)
PART II—Section 3—Sub-section (ii)
wifweant 8 wenrfita
PUBLISHED BY AUTHORITY
a. 1586] ae facet, Wrerant, Bers 9, 2013 /3THS 18, 1935
No. 1586] © NEW DELHI, TUESDAY, JULY 9, 2013/ASHADHA 18, 1935
faa aaraat (rated fort) P
aftr ag feeet, 5 Geng, 2013
(arr)

SIM. 2081(8)— Wath, AT Te TAT Got ae Het H Aaa A alert Herarea H tare sie facia aaa at treet fre. area Torey FT ara ate atftueat Peofeers ate Tere Ft aeare F
ara area F 8 fata, 2011 at wae Hare (Pra Sah ae HUTT HT WAT B) Ve Beara Hs WF;

Ae Tah, TA HAL H Teer Str Ft arér|a 21 FA, 2013 Z, Ht FH Ta Hee F Ara 31 .
& fas 2% Saat HW aay, Hae aA ay Her H few safe srqat w are azar aafara oie oot aed & fore afeepaarat 4 4 are Ft afer Ft aréta 4 are faa 2:
zafau, wa arrac afafan, 1961 (1961 ar 43) At ater 90 arer vaca ftaat ar vaTT
att EU, als AH YagERr afagtaa edt s fH area wrasa Ft aeare Ae afuea |
Rofera ath sera At ara & She arg ae ga Ut ae Het -H Aaa F aret Harare F shtere az faedta aceaa at tat Fh foro sa Hare FH aot sada, Sar PR cas ara Hers Seas F
fear war @, aed Ae F aH 1 aa, 2014 A ary Pee ST)
[afeepaat 4. 53/500/138/2002-Fa.4.5.-I1]
Tare, aad alae
3013G1/2013 (1) .

"2 THE GAZETTE OF INDIA : EXTRAORDINARY (PART II—SEC. 3(ii)]
ary wd tht ox at ter F A Heras Haare se .
Was HITT Fl Cray H fore
| AS THTST HT ALAC
HT
set ahs wrsy FT ALHTT
& that Hat
Aa WTS Ft ATH ae Tans aRSe ToS Ft aH By Wa ST Te HT
a aae Ff atet aera & after Ae cates aaa AT Cra FH fre gar sat Aart & he anfite aearn at Terat 2a At she a way Here ova ara Ft cea A, Peart aera eee:
TIE - 1
after orfer ae were sa afta Fe aA EET AT afaarartt crsat HA Peet wa sear stat
Fart = |
HTT - 2
after Bx
1. ae were fet afterart ase agar cae corite se-vart saat cardia ofan art ara wae Yoh oe are ae at B ada F AT |r, are & Peet AT aes a
AMT ATT |
2. aa aaa aaa aera Fae Fo ova afFearat ae aT a aT A GeraT art gad Haat aaa saat At pa afsat ox wet aed Sa ay, Ha Gt ae Asay ay I
ATA ay ste Ooh B aeat ge eee ae ast Het Ate Het HT ary we Got ae MT AT
att Sa FATT STOTT |
3. fart Ager He ae ae HUT ATT SMT, FS: —
(F) aea®, (i) array, frat sa oe art aver aferare ft oft 2:
(li) TART ; (fra sae are aredia ae HET ATT) ;

- (at Ieee 3(ii)] AA ST USGA: ARNT 3
a . @) sea anes, (i) «- Brdare By Tso SO (SEquesl @ ara tere Ff ore wadidterem, sreara - .
ASAT); (ii) aafee arr we ax (fquedt a area tere St ara wala fda -
MWSaeg):
| (ii) = atraret opfeeat oe ow (sae a are tera SF ara at Ushlsera - aaa);
. (iv) ararfsra acer Gersar et aH (Squad # ara tera F ara SF ata 4 aT
| ATTESTS AtATA-ASTTATA); sz )
(Vv) Seftor ae (Squedt sara Yara SF ara ret TET - ash); (Fret gerek are “erates Ac” HET ATTA)! ,
4. ae were Pret At aed seer aera: aaa eT ae At aT aT OT IT
eearart faa ard At ard & aeare fererara at & Rep sear Sars Fara VT ATT TTT
Afearerdt xsat & eer aifeerdt feedt of wecaget afadat & aaa A ua gaz at aergqrad Hot a sas ars -aTst Herat rat F Pu ae Mtl a ATH - 3 .
ararea aRearard a 1. SS aT He TH Aas F seq aera a aT:
- — (%) “ATR” er a aS F - BTS HT SAAT A gad Saas aaa AT TAH SIT
: e arse as & afaker are of aq aah aa onffe 2 Arad aq ara 1 age ae ae} ahrana ated area ara oar stacheia aq & aqart Beg HF VAT
aera ater, weg afar aar darters F
(@) “sera” gree 4 ATT e Vers atta wes a ae wefaartt at F gary
. Fran ore at ae Oster FH arqart Ae SaaS a TATA Tray WATT
afrarct % sente arqaectte eta, wat aa ofa 2; (tT) “wa Afeararé casa” gar “gear afaaraers asa” great ar at cast Ft atarax
AIA WUUST IAT Fars attest TTA F
(q) “aafer” sree va A arg ahs, are aeadt, orferat ft are deo aie BYE Bea aT
aifet & fore aafera afaarardt usat FH yee aca Brat H Ast WH STAT Tae F
Sy Hf aaa war 2: |
(S.) “weed” gree & are fanftre Pare oerar arg aa ahrra & fred He vata fere ua Forfa Peare & ea F Arar ora 2; (a) “sera” greg fare ware Hh Hare HT HLA TT AT BNA; .
(3) “wa afeararet Usa aT sean” Tar “gaye afaararé Use aT TaN” seat & HAM:
wa afeeraret use & ft Part arc aarfea ate Set gar gat afaararet asa F
Pret fared ara daria ars Sara afar z ;

‘4 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]

(4) “staves ararara” seat & afta & - wae afearerét csg & feet sere art ohare fed saara saat arqara aret oRaea, fare sa feat & wa Sera arezaT |

agama, sat gaeCfaeraret oe Oe Otte Ot FaTaT OTT
a; (a) «= “aera orferaret’ cree a afta z (i) area: fa ah, area acer Sere Saar fee fafa; (ii) sere atRevea worse F : fae ats carat te wreta aaa sear ofa ofatate, (a) eet afaeraré cee & ade F afte” ree a af ez:
(i) ref wes a fererarét cree Ft osteat aaa anrteanr arco Het are HTS Sah; (i) are fafa ore, arftert ak deo, fra acd ga ave ft Bfaoa fat afaarardt casa F rae Brat & oe Src aT;

(2) “He” ree A dat haga aed ae eT Tevafaa ax afte 2, ced cat

| tet are cae ote vat Sr, at sa eet dae H Pet ger aera aH HH Heel H Ba FT, fort OF Fe HOT AY Sa Sl AMAT Sa Het FH Aaa F oT av sess Bray AAA aT
aa ST, (3) « “fadtr ad” sez a afirra2:
(i) wea eara sd: wH ate a area ere art fads ag, (i) SRT are HF: aaa aH are 1 Trae at ae Ss are Heys aT siz arg oaferat & ares F 12 ads Ft ecras sae | ,

: 2. fret afteranét ose are wet aH se oe aT ary fae oA aT ee 2, Fa TH

aad & aera aafera a at, sad sroftartte fet ores ar ad at so AT sa at wart % fers se crea, fore oe aE HUT AT STAT @, H TAT sient Sa aaa ear z at ae at Ta Tee ary Pee ors aret ae ara & sents are ae at ae yarst er
OT Sa Usa HHT HATH Sates aT Ta F |
ATs — 4
fart

1: Sa Rt H aa “oH afaararét asa ar fart” sree ar are fart wat aah a 2 fre ot Sa 9 FH Hr F Sea Sas afeara, flava, forse & cara, yars-earat aay fart Ua St Brey a He TTT AT HT = Se gars, sat ae ces ae ea HE
aaa So-rarT aerat eared snferacor ft orfre At, aarft sa ores Ft are Tar aie ofrea adt erm fra ot Fat Sa asa F fea arat a St areft ara ae a ae Ff
STAT ST AAT FZ:
2. Wet tears 1 F Sadat & arco ahs are af Tat St afaarartst casat a fart a, aet sac share Pqare aa St eft

{am |]—ave 3(1i)) ONG Hl UIT : SATURTT 5
a) 9 - gat ae Set cee ar Rare ara Se Ga SA ws eat Prava-qe Soe 2; afe oa rat ft asat F are eart fRave-qe sues A, dt ag sa ase at we PRaret

Arar area, Bras ars Sas aera ate aris cate afsax F (Aecrget feat ar Fe); a) af sa cea a fired sas Beat fea Pea Z, ate vet fear or aa at waar afe se stat creat HF fret Ht tse F are cares frara-ye sree Aet ST, aT Fe sa asa ar ws Part aay aro rat ag areas tear BF;

q) af ae wana St A ase cae A aaa sas B eh At oss F aT aT, at ag sa asa ar Pare Brat Seat fara ae urease ; a) «aft ag arat ft cat ar ates at aera saat & Pett ft arse ar urftes at at at afaarartt csat & ae ofan oreecite aeafe arer get wet ar Fore HAT |
3. Wat Sa arse & heros 1 FH Saat & are fet ae a fre are eae aa afaararatt asa ar Frart A, aa sa Fae Sa tres ar rare arat ser rast Sara yardt yaa eae eae 2 1 afe sa ose at atc vet fear or aaa ef fread saat sardt sae cara fea 2 at dfaarart asat % ae orferarét ureecite: agate 4 ca
WI BT TATA HUT |
TTHae - 5
caret eearesy

: 1. Sear wears cart dearest ge ar area ara} aa aaa cara 8B, fora art feet Sears ar areas BETS: SAT sere: Fat Arar F |
2. earftdearga ve & fastoaar PATS after ait :
(#) «- Water amr BE FATA; (a) Bre Taq; (7) = - Ars Hrate; (3) BTS HITT; (=) 9 ere arta, (3) «wre fast ae:
(@) «Pare aes A aafra are VST, TT gael FT MUSTO afaare year Herat FT; (a) ote Het, arraret aera set ears et Bee, arferht, avrardt aerat sare aaferet array PT TA BT; Se (A) - Ae GTA, Aa Baa Te aT Bat, Gara sear aware efor earaat eet Alea srpiaes vara & freattor ar BS SAT FATA
3. (&) He waa-eae ayer Frat, yearsa suar dated Water aear saa safle wade ariaars adt cn cart dearqa aan afe tar waa cae, afar ara

; ardaary 183 fea ar sae af aay TH et |

6 THE GAZETTE OF INDIA : EXTRAORDINARY {PART lI—SEC. 3(ii)]
(@) Fame yeaa wea, fread ca vate Aq Tee A at eu ada sea aT
aifteat & aera a fedt sea Ft cerasff Aare one J weg Tel sa HaeT F
feareary fedt 12 ada ft wate & sftac ga frarec 90 fea a afere St wate ar araferat 3 fore Bar 3 tax are cach at (Sat erat dae aes Bq) |

4. wa Hqeae ydadi soda & ara ev At eae dear” ge F fPafertad at ofa set
AMAT STAT :
(*) saad aafeea area aaa Wwa-aeqai & ara aver, vests HF Taras afar aT SETH AT
(@) Ara avery, yeasts H WatsaTs Sera & aafea are aaa weg aeqat F fart
Telh HT CS-TATS HAT; ; (7) eft ae sere art Saat dare feo wa yaaa Term FH ATs Hay WA-
aq at 3 Fath AT TA-TATS AAT, (4) Sera & fere art aa aaa ar at Ha HAH fer HAaT BAA WHA HET
a fora arcrare & fart fafeaad cara ar Ca-tala FRAT; (©) san feu tae ores aaa aes cares & fat ae arias at AAT
warsrars ararars & fore Fafoaa cara ar Ta-Tas AAT; (4) a-darars (#) 4 (S.) ae A fated Fae est art-earst & date & few araaia & fedt fafoaa cara ar ca-cara aca, and fH sa aa & afooaeset arerane & Fafa cares ar aes ererHerry Peet orcPeaew aT aera FST AT eT |
5. tah 1 aK 24 saa at & ate ew oft, wet cada Ahrra & Peet afew, fra oe Pas
7 Ary Stat at, A fra are ahs aa afaararét ass & fet sere Ft ate a oe aera ot
Hard HAT @, Ael sa HaHa *F dae H, res sen ah vers & few wea 2, yaarfeafad aftarart wasy Ht sa Sean A earl aearaa ar STAT AAT Sua, ahs We oats aT:
(®) sa see area va wes F afar aera Hes HT faa a ST OA as ATT
sa oifeeare at wart ft aca a, wa ae Pa oe Fr afafafert Aeros 4
sfeataa sa wfafafeat ae diffe a at, fire afe ae arctan & we fAafoaa cart F
Aeay & TANT HAT %, Hl Sa Aras &F Sadat F aefta ara F ca fosa ears FT
UH Cars SEAT AKT TATOAT; ATT
(a) tar are srferarc ove wet &, Peed ae fax ft areca searateafed usa F 0a are
AAT WA-qeqat wy tera Taat et ras 4 ag Tera Ft Ae A Area Aya qoq-aeqat st frafta es & feettatt aca a; (tT) ead, Seam % fore haar saat aaTaT Waar veatfeafaa asa F areaat art aT
SST WTA HLAT Bt |

; Lam []-ave 3(ii)] UNG Hl USA: STATI ; 7
a 6. - a ASA H Yad Sadat F sre Eu fh, ws afaarard asa & feet ft sas st Te:
Shor wet Barat Ht asa, Tax afaarard usa Fo us corft seraa a ara ath Arar |
arent, afe ae cade eftaa are feet use, Fra ae tears 7 ary grav By, a Pra Peet gaz oafts & areae a Sa area TT He A A ar Siaa vas aca f azar zat fees stfeat ar
STAT HTAT F |
7. feet sere ar feet aaah ase F ary ce are BT east SETI HT SAT Tel ATAT
ara f ag Sa tea F fet care, aaa afters wae aera cada Raa area Peet area is .
AAT a Hare HraT B, aad fH VS sah Aas HVA HT HA ATTA BT SF FTE ET | ;
. aaa, wa Oe Peet wate & artes Gore: aerar TT Yotea: Se Tera FT ste a few are eT, aT
. Te Se toa F araTs & stent cada Shae ar Use wet VAT TTA | !
8. we aee fH are weet, TT we aaarard ase A fare @, Peet Ue aco at Paar :
. aedl & waar fest oh wert arr frafaa atch % ar zat afaharerdt cea st fare & aera
SY sa zat cea F (are feet card degra } araaa a sreyar seq) arcane Het Z, Hl IA
aati Fa feet Heat at cae: et eat er caret dearas Tet Ara TTT I
aoe - 6
TTA TT F HAT
1. wa dfaararét usa & fet Fars arr gat afaareré asa F fees aaa arata &
WA AT IT SA FAT TST F HL TTA STAT
2. waa arate ve aT at ast dem WY ga aftarard asa & arpa } aaa saa ATS, frag fearcrefta arae feaa 2&1 ge ce a, feet oft area 4, 3 ofa eh - eet ara &
waaed & wT Ht arate, He sie arhtaht A oa Teas aie ToeHe, Va aferare Hert wey arate aaeft arava arpt & Tose ay Std Mt, wat seats at ars H ater ae ahr
HUST, Are TAT sea orplteH aaraat tea & fore sear atest H aferare H ahaa H ST A
ckaddty aaa faa serafiat & aferarc, wera, atere at arqard araet aaa wT F
, wet ATA ATT
3. tome 1 sade, wae aeahe & yeaa saat, a fears ae BA aaa gas feet steq
; at HAT A Saya Sts areal ara ae Ht ay ety |
4. ters 1 ah 3 aeade, et vem A ase aah A oa ae aT eas aT
Aarat & Frearer & fore yas arate SETH SF ores ars Te AT AT ST
aT — 7
BRAT F ATT
1. wa afaerardt asa & feet sare & ara oe at Set tes Be TT eT re oe
. ae san gat afaerard asa F feos Peet cart seares & arera A se uss F arctan set oo, PCa Sli als Tee Sars Tae TA SF Hare HEAT Bl A Ba aA aah ae gat aa F tt eC AATAT ST aeHAT 2, Pq sah Aral Haat SaN ater ae Ht a a Gt va ea ae HT 3

; 8 THE GAZETTE OF INDIA : EXTRAORDINARY {PART II—SEC. 3(ii)] .
2. terre 3} sade & afta wee gu, wet us dearer aes a ae vee ee aa usa & fer fret caret sears & area A A BTA HAT BT, Fal Wea ares asq FWA
EITaT GEMTTT HBT EU ATA, J aA ATA STU: rae BA AT Ara ga SN Ha UH TATA
ar sae ordit-gqedt weteafeat a wa wars ar erd-qera ertearat a ont eu arg sik Pa
_ saa a at 3 se sae } ara Gi: ads | Fa He @ Rae ae Us eet dears a |
3. feet cart george & arat & Prater act 8, va cog & ara & saaat sik va} .
ararat & sealias sa as At wet Fh aque at orecht, at sa cart dearaag & yahraret at .
fau ara @ Brad ge var ware ae arta wa area sora ore: oft offer F, wet sa sa Usa A Ta Uy HF HT Saat F Sadat site sast aha F aqarc fw aw at, frag eardt dearest feaa % aaray aera Pea a at |
4. Ser wae afaarard asa Ft sere & Ha ars Ht Gas fafa al A wares FH Hae TOU
cart dearest at aA area are ar Rater aa At yar a, ae ears 2H ae Vaasa afaarardt usa & wafer wart vate a at rera;7y yo ara ar fate Her a aftariire wet eet, gate, ware & fore arqars we fate wet art fe sear afters ga aqeas Ft fafea fraiat ® ape SMT |
5. als aH, Fae Sa are a feet eet dears Bt gat vet ara ae fH va eat
AeaTT Ft TEA H Fw ATH AMAT Wy-qequ GAs Fi
6. aad rat & waters carht dears & arco gu arat Ht aa aH aaiqad set cafe a
& Prarie Pear sar ta, we aH Pe sae fare arg Sra aa date Bre set BT |
7. Wet arat Fo are Ft Det ae ofa att = aa ga HH oT qe F aa F
feaaa fear war %, cel SA Aqeeal H Tosa sa ape H Taal & warlaa ae BT |
HTS - 8 .
4.. wa aftararé usa & fet sea aro aeacasta ararard F wear waar agar &
Warest & WS Slt are ATAt We Hacer Vat Usa F HT TAA STAT | .
2. afe feet wert sere ar wardt vae-eura Ua WaT UX Bl, da ea Ba afaerartt urea & fee ara set fsreat cerara ft ate arcane fer St aera afe va afaararé asa F
vat He ate areas A Sl, At sa va afaarerd asa 4H fea ara se faa Haare aT
| wWarers wan fraret ef |
3. tere 1 order Peet ger A anftard, feet dae sere aera fat access ware weet a ore arat ox At ary StF |

. ‘ Cart Hare 3(ii)] GRA BT UST + TAU 9 .
ATPASE - 9 . .
. aeartt Faq ;
1. wer (=) wa afaarart usa aT are Tam Fae afaarardt wise w eT sera & sae,
Peay TAT Got A TAT: AAT HTTAT: ANT TAT S; ATAT
(@) «= - Fs aah, wa aaarard ues & Peet Gers ix gat Sara tsa & fet san & yaar, Peas aera Goth Ft yeqera: er|ay aeerera: ATT as F; az erat H & feet oft aaear & ctat serat & dhe ore arftrisae aera fara saat F
Tat ort Ta sryay wars ar F A Va vat a fre, a cada saat & Sta eet oot at tar arg oft aret at sa rat } ae BA St feafe A sa Terai FA wH Tears BT Ta BAT
Brat, Pere Sa Tate BT ee THe ore aT BoM, A a ara Sa san H aral F a
Farr HT ah Ie Ta TL TAATT HT OTT AT ET -
2. were afaarard cea ga reg 3 feet gare & ara Fo sa oral at aftafers wear & tz
Tea ar aarat @ fre ax gat Hara css} Att cow ee Te gat trey A HT aT TAT
2 a sad aftafee Peo qe ary ta ary wt yadifeahee cea ® vers HT va feats F ore gu eta afe arat serat & ats aarg we aise ace ft ate St cade verat & aha arg ae eat, Ta FE FAT WSF Sq ATT Te Sas wa ae Ft afr & aerax aaa Taras Ke .
za ware & aaa at PAfsee aes AF ea wae F area sagat at ware we & cara A caay
. erm ate aff sracae et, at dfaerart osat haere oar wa sat are vere BTN
3. terre 2 sade ast ary ast ett wer arias, saratas aera seq arett aretarfeat a ary afte art sara war & fH wet terare 1 *® atafa arat a sarah Fl agray at FH
arareat & aatite seat Fa oH erarast, aT Tre Hara Hrrgarnc Ft TE rarest F Aa
. H ates & fora Saat BI
ATHS - 10
. aTaTT
. 1. 7 Afaarart uae Ft frat fat eat are gat afaarardt urea & Pet Faredt at ear fear ae aster Sa GAT Tse H HTT ETT
2. aarft, te aratent oe se afeararg area F oft site Te Tee TTT BH STATS HT ATT
aT ana fSrearer arate sar Hea arelt Heart ws art 2, wea afe arate ar fear cant weg dfeararé usa ar wa ard & ay ga ware ward et arial Ht aH TY H 5 share SF
afer ad gem ae eras sa arat H tater A ae He acres Bl wade vet wort Sah a arate say fw ae FI
. 3. Se ase A gar was “Arai” ve at afore dat aera oer afearet A ore arr a ait ara At anftarttat & aro ard a St, ake rey afta 8 wre ary aS fre ae aA HOUTA a
| areca any at & Ht se ase sara } aaa Ma Ba ars Te ar are 3, rah Bac |
aed are aeot wap fart e1-
3013GV13—-2 ae oe

“10 THE GAZETTE OF INDIA : EXTRAORDINARY [PART Il—SEC. 3(ii)]
- 4. terme 1 aie 2 & sada sa ae F arg set att, afe araiat ar Rash cart ws .
afaararét usa ar Praredt aa % are gat afaerard usa F ager ferag we carl dears &
' Aa & Hretae HAT B, Forest arate ser wet are seat Fart F srerar sa gat usa F
fad frat figaa cars cade safes Aare vers aca e att fra aeaha & dae F oraiart Ft ramet at ardt & aet ae sa dare Et Gearaa aera faa Sara A warat By a aes BI :
tet feat A, reyeege 7 aT eqeee 14, star ft are By, B sade ay Shh
5. - wet are Hee, ot wa afaarard asa Ft fart 3, qat afaarerdt asa a ara srrat ;
WT WTA HUT B, Tet FAT Use BETH are sear FHT AU arate Te, Peet Ah ware ar a aT
. ATTA, Ta TH fH CA Arai Ta TAT UST % Pet Pare ar aren few are BT, sera wa ow PH
fora arate & are F aratenl At sarah ft ort a, ae sa gat cea a fers Peet cart dears ar fret frre cara & vara ST A dag SB ate a HT ered & feat arate HT STAT TTT, are Her fu me aaa aaraT saga aay wT a ar aifars wT S Sa sat crea F Saya HA
aTet ATH AMAT AA H wT A gh
WTPSE - 14
aT .
1. wa aftarard casa A sera SA ares aa gare afarard cea & feet rare wr sar fw
TU SAT I TA TAL TSA HHL ATTA AT AAT
2. aartt, Sa ware Hh sare ae Sa afaarard usa F aft atx Ba sg BH Sat H aq ae waren ot aaa Bra usa Hf ag gaye star 2, faq ate oore an Roan cart eat afar
: arse ar fare & at se ware gatita we, sare At Het THA FH 10 vitae a afers vet shi
3. aa 2 & sada F ete Eu A, ws Sfaarards sag F Saye sas We Ta asa A a F
we wa antt aerd fe a freaferfae & are wre fear wean a ak feast et & aaa caries F
CET TAT BY : :
me) gat afearard usa A aca, sear HTS todas Sa-sT aeray Hrs carte onferacar,
TAT
@) (i) area Aree, area ford ae, area arara-faata de sear asta ara a; ak (ji) Zea } ae 4, dat dea ta ged, Fat A or Raheem ates 2a sed, dat fediearhtat Fa sera; weraT
. 7) | are area deara fre ax afaeraré asa & fhe aaa wifderhat ero aaa-ane a at
H ASTA-TeTT H Sccremaa eNta Fe ST
4. et wes F aa - Taw “SaTSHOR ore F HAIG B - veAH THe H eT Aaefl ara A Ta at, ae & den are yfeyea at azar al ate are See eT-araT Hy A afters ar HS
— aferare sve et area ef at siz fasta wo a acardt vftateat a, wa ara ate aercat strat aam-Tal & ore ora fread tet wfaaieat, tecat saat ae-wat A date Hitters att qrenre after at Prorftat ararnft & fore artes aaelt wart at ga anpeae } vahora & ferw sare aet
AAA STOTT ,

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° 12 THE GAZETTE OF INDIA : EXTRAORDINARY. [PART II—SEc. 3(ii)]
- oat & yfener Ff At ae fatto ware Ft aeraftan % ceeq sat ce were BH aerate 14 TT 15
H sated tarat & fore Ft ve serahrat nfre wet S
4. toe 1 she 2 4 sade va feat & ory set att aft cafeeat ar aati Aarat & far cera at feet caret, at wa aftererdt tea ar frardt ata & arco gare afaarart ase F, frat crafeeat ar aatht Garat & fers ite sexe act Z, set oe feaa Peet caret dear &
Hea A TAT FAT F ATAT SA FAC Tes H set Wx feud feet fafeaa coat A aA
sate tare feqrfea acar & aa ra afeeere ayer arate & daa AF crafeeat ar aattht
Sarat & few hte ser ft ret % a a cant dearea aaa fieae cara & are yard wa a ara 2 ta ares FH aarfeale aqese 7 aaat eae 14H soe Sar At area BY, ATT Sh .
5. (%) wa afferent usa F cafeeat car aadiet Aare & fer ta aa Saye ge art aint, wa aernat cad ae Ces We Tras So-waT, earthy onferart aaa sa cea ar aE
frarat ati carte, wet cafecat ar aadtht Aarat & foro Fite ser wet aret orf a1, are ae
Pret afeararct asa ar Fraret et sxaat adt, ga afearerét use F tar are car qe aaa are fitaa care a, Bree ade F crafeeat sera aati Aare & few fire aan wet Ft fratrarét frarg we at, ate eft craeeat ar aattht Aart ® fer Fra se eee dearest aaa fafosa cara art dea Ft are A, aa ost cafeeat saan aati Aare & fern Fra sa asa F
saa es art are fares ag ear aearaa aera fafa cara fea 21
(@) | - Wet 3o-Avars (%) F seria crafeeat aan aattht Aarat & feo ite fet ose afaarart usa F saya adt erét % ae crafeeat warm, saat yaar, afefart azar aorta & data & aan aattht Sarat % fro rae fat we afaerarA cea F feufea ara a dated & at crafecat aaa cath Aarat & fore hte sa dfaerardt cea F soya Bs art arti
6. - Wel, Herpat var aarti cart & dhe aera aa erat az fat aaa ones & dts fat fara ware ar Hae Sta are crafezat aerar gat Aarait & fare re wa, warfare .
aaa 4 free foro ag sar At ord 2, fatto arco a ga afer a afer at art 2 fra oe saat At aqafeate F aernat car feetartt cari arc venta at we arc, aet ca wares srag Fae shee afte cae ae ary eth ta area 4, serafirat ar arfaes art ga ware ay Saat Hl ATs A ad eu, wer aftarars cass FH arpa sare HAT SMT |
TPE - 13
osthra aRrara
1. wares 6 F sfafea sik gat afaarart aes & faa sae arate F aac a ws aarart cise & fret rarest arc ora aftarat We Sa Gat Usa F Ae TTT ST aT
2. wet aa aoe > aa a er are aftara oz, aT we afararét cea & fat sere FT
ane dfaxraret wea of fore Pat comet dearaa St arcrarx date ar we fee f aera Pett

; (am [leave 3(ii)] ARs SI UAT : AAT 13
° Risa carat a dafea tet wa ache F.aaco a we SM are afters az, at ahs ws afferent usa % fed frardt ar. gat dearer usa t cada Aafee tarsi B waprary sree %, fread fet te earth dearcs (et seat GT sera FH ara) saat fAfeac ears F
HAT F Bra ara ahaa Ht hea S, Ta Gat Usa F HC TTT ST aT
3. Heats ararara FH Vee ST aT HTT AAT STATA FH ACT A TAA TA THT |
sept seat & af de, ae eS Fh a re afer oe tae on afaararét use & ae aarar aT aaa, feraar fe tacorenat Pare 21
4. fet weoeft aofhra cele & act & sac a ore afrarat ox forest arate F gaara yeaera: aerat averera: fart dfaerart use ¥ aaa arate fers 2, oe Sa asa F ae TT
TUT
5. fart aot, ott afteraré ose ft fraret 2, ox tras: 4 Gt ofeafea F waren sat F
say S we ahyarayt 9 Sa Usy FHC HATA ST AAT BI
6. tras 1, 2, 3,4 ar 5 & sfeafea acafe a fra fet oft areca & stare 4 oe aftrarat ox ae sat afferent asa F ae aarar at aaa rar sacral ws Part 21
APE - 14
1. wa afaareré usa & feet fart arr arrears aareitt & freares aaar sat vars &
Pada FAST Ae TY HTH F WTA Hs We Fae GAT Usa F aC AMT A ASM, WY
frafefaa ofteeraat at atsax ae tet are ax gat afaerard use F ft ae aT ST aT
| (#) af saat aaa a@rd-perat & feces & saherard, gat afaarerh usa A wa feae cart afta eo a soetee & at Sa arse F Ta gat wea Ff hae Saat ara ae St HE ATT ST
aH St Sa aa Cart HF HILT SayT |S AT TT aad e azaT
(a) afe gat dfaararét asa & sae cect At safe a aafeat date feet are aes St wate H eat Prarac 183 fea aaa saa afore fer et, at sa are F, ara H Haar Sad St ATT
Ot ST FAX UST HF HT TAT THT, GT Sa at Usa H Sas arr Preaies srd-wearsi A wa a |
- ‘oraarfis dani” 42 # cada Aanfta, arfefers, sara, Afra serar wrarea daft
| orararet & cada arpa are F |
ATS - 15
| quaatad safes tare

- 14 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)] . ,
- 4. APSE 16, 18, 19, 20 ate 21 FH Braet H sets Tad Eu, wH aaarare cess & fet frardt are feet Pater F date F ore Saat, aargfeat ste sat ware H aerate ae Hae set ase A at coh, we oe fe fratera ar freored gat afaarardt use F aet Pear war ah afe tar Frater frat war @, at ot others ser & wre ater 2, Fa We Sa get se Ft aT TT
wat
2. dears 1 & sade & arage, we dffarard og & fet fraret arer eat afaerard urea 4 feu ae fet ar & dae A ore afore ae haa weaifeafad asa Hat TAT SC
. aT aa, ae:
- (%) wranatl, cafe fade ag F aura aera sree ee Pet are HEA Ht Ut Haha :
arrat safer & fru gat Usy F Ue TET Ss HT Ha erHc 183 feat a arlers ae s; (a) afta ve fret ferators gre arerar Sesht sx S Har fHaT WaT z, AY Gat UT AT ;
Frardt vet ¢; az (Tt) orfterfra te Paett eet dearesy aerar PAiSaa cars art age wel feat sat z, FT
Prats aT gat tree F eT
3. Fa Hqeae F Yad sada H avaga, ws afearard css & fet Serr are aeaeesly
— aravara F epariera feed ae serar arqara oe fw we Praha & aaa F wre Treas ax, sat
Usa FHC ATTAT ST AAT .
| ATA - 16.
frasrat ft fret
Prearat ft Gta att get ate Ft aa aarafitat oe ot ua aftarardt tea & fet fraret are fat sect, ott gat afaarard usq st Raredt &, Fears ase ae aaen Ft ofa a wre Ft 7E Sl, TX Sa TAT Usa F BT TATA TT aa
| WPA - 17 | -
PATHTL Be Faetst
1. apes 14 ae 15 & sade & arage ft, ws aharerd ceq & fae fared ara -
ara, Sa fe arg tex, waa, tar ar gracias Horace sera feet aefteare Herat fact faorst & wa F gaze afeararé useq F fu ae ga yar aaa Aaiees aret-warat A ore
HAA TL SA TAT Ts A BL ANAT HT AAT
2. wat feet warooreaat aera fat faerst are aaa ga vere Ft Bfaaa A feu av aaa art-narat & are A oe ae cad AaltorraHal at faarst ar sve aet a, stra fat arg oaren HT Te |, Cal ara ae areas 7, 14 ae 15 FH Sadat H aage, sa afaarayrd wsyq
A ay saat aT aa, rat wartorrapat sear fest & ard-aara fare ara et
3. ors 1 ah 2 Baader Pet aoa aerar fart fest are, zat afaarard usa |
§ Ponta ard-peardt a arena ara oe ary ad aby ate eae afaarard usa F feu aw arf.

- (am Haug 3(ii)] FRA HT THT: STATI 15 ,
Hag wH at sat afaarard asst ar criss so-werat ar sas core wfearkat Ft arate fafeat arr ante af 1 va areas A sa ara ae Hae Sat afaarards asa F He ATT
ferret ag arcorrpat ar ferret fart 21
WTPae - 18 .
14
apes 19H Sars 2% Sadat H eeqeiia, wH Sarena wea & feet Praret at Teh frat farsa % vfanert & wa Ff rer Ht 7S tors aie act were & ae TR ae oe Hae Tet
Tey HHT HT HTT ; .
AIRE - 19
1. (=) fedt aereré asa aaa sae feet corttes sa-rarT arerar fare carey orferacoy rer fadt aft ar sa asa aya Ta-THTT araT
o arferarcor & fore FF wg Sarat F dae A arar fw ae tera & fa aaa, orgs gar eat were FH eT
. | urftsrite az Harr Set Ursa HA He aT AAT |
(a) -aarfe, ta aaa, wrett ak aft var ® ae ofa mw Fae
| gat afrarardt ase Fast ae or aa, ahs Aare sa asa F at ardt
&, ae safe sa cee ar us ard st, aT aT
(i) = sa cresy HT TH Tees 8: TAT
(i) Fare Aer we | Va Ts > Fr sa es a Fara ae aa aT |
: . 2. (=) fat dfteraré ase azar ges ft cerita
Sa-sart array Peet carte orf are arerar
° . Bas are gfera fiteat Fs feat ate at sa
. Use BAST GI-TATT Bayar wae F FT wars
; At ws Aaratl H daar A sar Fh we fat Gera ax aT Ta Usa A HT HT AT |
(a) qarft, deft torg oe Hae get afaarart asa A acai, afe = ae a tT
at frarat cart utter at
3. ware 15, 16, 17 ste 18 & sua, feet afeerarh asa aeat sas fret uae sara srrar feet carfta orfeecr gre were we feet arcrare & Paha
H vera Ht we Fara Fh dae Ft Aaa, sored sie eA are & area afta gar tart ae
| : aTTPae - 20
WHAT, ATATTH BHT TTT HAT ;

16 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)] |
4. Be Whar, aoares ar ote sat at gat dfaerara usa a feet fattera, i aeaaraa ray Fat Usa H AT ATTA Wa sear F fereroy ar etre Hrs AT sat H WATT Sq
Sa Fat dsarared asy Ft aay Hy SF Gord Gs feet ws afrarard asa ar Paral s sera .
OT, at saat SA Gat Usa H Tas waa aaa Ft aréta 4 at ag a safes Ft aay H fore Va fareror ar etter ert & Ferg ore areas We Se Tat Tey H He Ss Ge we STH |
2. we aqeae Fae re |r a ora BA are ara ax Set eae F ary arm ae Bae are tart
. Se Sree Fee ee cer et FF a 8 gt FS oe rae ona Sor
; .
| 3. Sa aoa F vara & fore feet oats at afaararé asq ar faret ara se ate ae oq fade ag F aera sae ata vee fade at va ces F Pare & fred ag sear afaararet
Usa aT ART HAT F |
HTPSS - 21
fare
1. are fart of gat aftararé oeg aT ater Hea H eT Gea Ta Afaararst tsa F a feat ua ar fraret & serar ar ate aT ara att fever arear sisreror & carat area afeararet
: ag & sofere % a aqara ake aragha F ware va weg tisg H et aarafrat ae He a anft, ,
. (%) Fa aa wey H arer TE | Safest aT Tas wea-gram, fran vas Tivery wart a Pere sat Pew re TATA IT; TAT .
(a) wftafts, a ag feet Rap A wre wear 2 fra ae aa dfaerrd usa F ; areal &, afe Parra sah eoaaat F yeqet ST a GST e |
2. a seas Hara Hae Ut aaaraha aH Soaeer St at Teh fe us givert at Ge .
ara & for adhere Bt ara yarra wa a atfera & gerq Peet ft ara A are ae at sat forert ate ofsreror 3 watsrarey ca sped H ATM sey Usa A Sa wa anaes Ht faa a aararz ae aaat $ arate a afer at farm
HTH - 22
HT AT
1. wa afferard usa ® faeht frat st ara St teh ae, wet-wdt A sey ere af, fra az
Ba HUH Yate apeaal F fare vat Par war 8, Hae sa Use F Sere shih
2. thors 1 F sede, wea «6H has: 2 A aar-aRarite sae arate F oa ara a fa |
aa ae any wet git, ae tet ara aT oreHat wH dfaerarh asa ar arf sat & ara gat afaerart usa F aet fead Peet caret dearaa araaH S Hae HAT SF AAA SA FAT UMA
& aati flava fet fafoaa cara & cada aafes Aart froorfea sear @, gar tar afar way .
arate frat dae F tet are srar At ore &, 0a cart dearest aerat fafeaa ears B wardt ST :

; ° [am I]-ave 3(ii)) ARG Fl UII : STATURT 17
a aera 2 CA areas FH aes 7 aaa aes 14 H Sade, Ser ft arse Sy, ATT Slt
3. Sears 1 He 2H Taaat F ata Ew Ht ws aaarard css & feet Prarst Ft ara Ft acy, fora Ot Sa Here Ya arepeaat F at set At we B she St gaz aaarartt asa F seas st
@, Te Sa sae Tse Ft HT TAT AT aT 2
ATE - 23
Gott er HUET
1. weds 6 F sfeafea sh we afters ose & fart & enfhendia or gar afaarardt usa F fag sae arate are Prefta wh oe gat Usa F AT TAT ST TI
2. tae ae arate aren, at ws afaararét use & fat sem H cat dfaarart ase F fea frat card cearca ft arcrare aoe ar wa Rear & ayer us afaarardt usa & fart at gaz afaararet usa H soetee fret fisaa cart & aafee tet ser aay are gaz asa F a atin tara & fares & yates Freftea Git oe ae oT aT I
3. sacrsts aravara Fo aofera Serarat ate arqarat six WA Tea ae arqara &
warerd & data aa aoe are frefta wit ax saa set afaararést cea Fae aT aM,
Forerat fa tet arate anita eer aver sera Frat 21
4. fart afrararé asa & we frardt ft oft & att wea acal ox Hae Tet ase F A
ITA ATTA
WTPaS - 24
. aret arrara & earHcr Ft Fahey |
1. Set Roars Br eaTHETT Parent fear sre (*) aad:
#) Wat area ar are Praredt det are ore aeat & fra ae ca PU HOTT
AAA Tera H AL AMT ST AHA FZ, AST ea, Sa Pars Ft ara ae ae | HT F TRG
Haar fae ae ae Her UTA ae Het At aaqAhs wart FAT |
amare, tet wetdt, ge feu aa A yest aar-aafirs ae He Ta aT a ales eT
anh Brrr 4a sa ara a at ra ae evs F HT TAT TT aT ZI
@) et area ar ate Part tet Got oe weer at fra ae ee HF TTT
ATA Ses HHT TAT ST AHA ze Fel area Va Paret FY arate we axe F day A
sere F spay Paw re ey ame TN ae ett A aqaha wera BIT
aartt, vat werdt, ge feu ara a cee aar-aaitre ae Sa art a afew aet ant ot Sa Ystt arco st fort Ie Tees He TAT ST HAT FI!
(1) «- Wat, sa Here} Pet At Soar BH ere area * Pet fare are ora Ft aE
aa azar wa At Te argh ae area HF He A Ge ae ars S, get area Pee AT OT
Fraret #t ore art aera areata ae ae AT aaeriy Ft aay FH AAA GE WTA MT BazaT
ere eaeriy at dara A TaN |
20 yeaq:
3013 GI/13—3

ag THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
%) «Hel Sera ar are fraret tet ara wre acar s fra ot ga HUH Gat
TTA THs HPC TINA GT AHA z, Fat Tera, va Frarsh Ft ara ax ae FH Hae F
area H Her fae Te HTH HHT TN Ie Herd Ft srqars vara FAT
aan, tet wert, ge feu ara A vest aar-aaftre ae sa arr a ates ae art oT
sa arate H reo st rat ae Area FHT TTT TT AT ZI
@) «Wet Sera ar are Pare Ot aes ove wea St fre Ue ga He PH TT
TTA ALT FHC ATTA ST THAT S Fal Tera Sa Pars Ft ost ox He H Aaa F aa F
war fae TT HTH THT UTA Ie Het At aeqahs Wars HAT
aware, tat werd, ge feo ara a cee aerate ae H sa aT a afere set ert a sa arate & prey at rea oe Aa HT TT ST aT ZI
(7) 9 Het, ga were & Peet ft sade FH aqare Tend & Pet Part arr ora Ft we
AT HVAT WTA Al We ot Te Sars A He A Ge wa Slt Z, Tet Tera Pex oft Oat Parc
BT eT ars array Ost ae He AT TAT FH TAA HE WTS BT STAT YT HT Ta HTS |

HYraa - 25

aA-STaRIT
1. Ua aftarardt usa & afvat oe gee afaarardt Usg F tar are Hoa say aaa eft tet ars ater any vet At oresft at sa Hera a ate aedtaeft atarat a fra saat afi
ATCT St, TT SA Tae Usa H Uva ae fasta: fara & dae F ast aaa F ary ere at
FIAT ANY At AT aad Mtl Aqess 1-H Sadat ata eu ft ae soda sa Safest ax Ht TT
EMT St UH AAT stat Afaararet wsat F Para az Zi
2. wa afaarart asa % fet ser & gat afaararét ase F feos eet dears Ie gat Uses F WaT Bre HTT AY AST Fea TT ST Sa a Css Sarat We aeT area at aed Sq AY St Aret HUTT F HtaTHa FA ATHA Sli SA TIsa Hr Ae set ast aaa aren fr wa afeeraret casey & few ag araaac 2 PH ag gat afaarart asa & frarfaat ar, wa Tats fre sat fafa saa azar aftarhtes farstrerfeat & foro fet ware Ft tat oatiaret Be, Tet saat Hetheat Fi sept & at ae aos Frarfaat Hr Far 21
3. UA ATA FT GSH Get Aq OH hears 1, apes 11 H eras 7 AT ages 12 F
Tras 6 F Sta ATT Ste Z, UH Afsararht usa & feet saa are eax afaarart ass F
Pref fraret at ser fart ae saver, cach, caritht Aarat & foro Ate qar set aaa, TA Tera a Rees arat ar Pater wet FB watraresl set oat aqare wHetdi-arag sit aa Saar ara waatfeatad use & fat rar ar sar fear war et set ware oH afaararét casa F
feet see are gat afaarardt use & frat ar fee ae ae, 0a sears Ft weds Got at frarkta at & vated, Set oat & afta wetet-ares Sit, erat & yeatfeafaa ces feet fraret at vara farce efi
4. wa afaararé asa % saat wz, rat wh sere ar aaeqet wa a aT aT aifrs BT a gat afaarart tsa wa ar afere rarfaat % caries F at ar sae are Raa Ft aret FF, swaaifeatad waseq H are Car ae vet aT area aT ace Bre OT ater aet At sesh aT

: ° (am [[—wrs 3(ii)] TRA Hl USATA : SATA 19
sa Hay F ste aerate atest & fra aerar afts areget %, wt weaatfeafad wast wer sat THTT FH SAT IT TY At HT S AT AT Ht ST aa zl
5. Aras F de, Apes - 2H Basel BH ate eu oft, at ware BH act wa faa ary att

HTS - 26

areerita Here Fahey
1. - Wet are oa ae aHere 2 PH eH aeer stat Sarat creat Ft artargat & are sa
Te SA THT HC HNTAT STAT Se ANAT SANTA HTT HT ga HU BH Tra H aqeq ae S al ae
SF Usa F eae arpat are Srerer Here Te Sarat F are EU At Ara Arsen sa Afaararct
Tse Ber orferearet BT Weqa He aaa , Perea fH ae cH ard g saan ale Saar aaa ares 25 F tears 1-H ela aan 2 a ae HoT Braet Ga Afaarardt css & aaa ofa al Teta He AAT & rear FH ae cites 1 ga Brae A se artarg Ht gaa afer & de aut & faz vagy veqa ae fear svat arfee fares ohorsreqed Car wrest TAT WaT SST
TA FUT H STA FH ATS Tat Zl
2. ate aera oofeardt at safe shea at siz aft ag cae Peet datos za oe aga
FAAS FT, TT ae ta Hear % after Ht sf a Tt ca Hae F age aet Z, zat afaarars use & aaH oiferaret & are oreeaite agate arr sa ara Bl Sa HA HT WATS HUT Fa sare fae ae fet were er afaarerdst csat % caeeht ara F Pest wae dharet H are ev sft frattras far sro
3.00 Sear At grag Hes aaa Sa TY He FH HS BSargat aaa stare eT, at afaararét ursat erm orfdeart Se oreeaite eas F sa Hes Hr vara HOt J Sa ArHat H off eet
HUET BT ST HET FH fer geeqe faare-faas ae aad & rast ga Hae F ae aes Ft 7S
Fall
4. Pret Horaret > afore a Hrs wae west yas Shaerarét casa & aes orfart

; TH Ae H ATT Mea Ta-oraere HT THA B1 Ta Pare & aia srara-wara Bq HUI HT ea fea

H eat stad wdta era & at Sa Ate FH Bara-wara Bl afaararstt ceat & aera orient &
afatateat art war ara & array & fat aT aha z |

ATS - 27

AAT BT AATA-TaTT
1. afeererét csat & were orfeerdt tet ae (zeavat aravar cearacit Ft afesrarfire ofaat afea) ar arara-vera Hey ot fH ga Hux FH Vaal Hr aaar afserarét uss ar va ari
& dafte ataiee ara Bo its araifas wet Pre araeae 2, wet aH FH as afta
TATA STAEAT SH HUTT He wae TST 21 GAA AT AATA-Warsl Hawa 1 Ge 2 ater vfaafaa
Tal 21
2. Afaarnrét sa are ora ft es STS BAT Va Us & aah erat sens ora aT
aaa et Ta aRelt arosth six sa ae sa Seat aerar wrfeeereat (ararera site serra
Frere ofa @) at cee Pear area ST ee Sela Aral aret He FH Sar H at ar Fae ar
STA aah eet, Tas vada sera afta aaa FH aera afta a7 Pair aes ar seep

20 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
AT aa a sae a 0S oa or fears aa a Saat ae DS St Wao & fw HG J ee aa at arate eararers At artarteat aerar sath Prorat F gene HT TAT
3. fret oft feafe F tears 1 & saat ar arf feet afeerarét asa ox frafefad ater
STAT et SMT :
e) «Sa wear gar dfaarard ase & arpa at sorafte yar a ee ae serahta
SOTA HAT ; , :
@) oo Od gem (fas cerae aera ceca Ft aferarftre sftat ofre 2) Ft
BATS FLAT Ht SA HAAT Gar Afsarart wey H Hat F Hela aaa vara Ft aTaTeT .
feat # ser et 8;
7) 9 tt aaa Ft werd eer rae HE OT, ara, stents, afew azar saraaras, TA ara Sarat Whar HxaT qaaT owHe |rdt at, Preval yee FAT
ardafte ae & afta at (asx afer) |
4. se wea aan F afe Peet afters ose are feet oat ar ore er fore arate frat aay 2 aT gaat afaarart ase aaa Ft we srvaret BT oa Hes FH fers art
GAA CHA HA Ae TATA HT STANT HOTT, ATS SA FAC TST Hl AWA aA HHT Wasa F few tet aaa Ft are aaa a at | Pract area F aeahea arhtee terars 3 Ft dora % afta
& fereq fret oft fete A tet dha ar ae ort vet err fH afaararét ase tact cafes aaa
Bars HEA A HAT Hea & PH Vt Para H Sa HE atatts fa ae Z|
5. fret ft feafa F tras 3 & saat a ad Fae cafes gaat Ft args wet F aa He a fern feet afeeraré use at aaqute at & feo adt are som fH aaar Pett aa, er facta dear, fart ostet ar fet aaret ara & aca ated a7 cafes & ora 2 a 7 fet antes & cafe fea a aafera 2 |
ATPae — 28
wet At taett F aerrat
1. afeeraret ase coreg erat Ft aah F oH gat HT AeTaaT Stl We ASIA Aaeas 1 Ge
2 art afaafte vet 2) afterart asat & aes wrferart ca aqeae & aaa At fafa ade .
ented art aa Ht aH FI
2. Fa Apese H aa Wa wes “WET aa" aT avert afaararét asst, axa sat cette sa-sartt serat cardia orferarheat Ft az & ere ae att fey act az faa a
@, Wel TH StH Hs HATA SAT HAT SAAT Hr Heg area rah fore afsararst esq yet FH
ara-ara tat cif & sate sare, vara a-ss she aa aay Aer H ater Hq as FI
Pref oft arr 2a erat @ Ste Sa Ha Ta Usa FH HTT F ata SAAT Teeth HT TH ANT THAT
aa Sa Uses Ta HT SA Usa HF GaAA ose F aqaa ae gat Afaarars wea F AaA
otferaritat srr aaett a watsrarst esters Pea STAT | Sa WES aa BT SA AIST SPT aT

, ° {art [-wars 3(1i)] TG Al UST ; STAT 21
eae HH H yada ste aye, aay fH Meg ray Ga FAX USI sr UaeT aay 7, F faa vasa ss arpa H Tat H arqare Sa gar afaeraré aes are agar Pear STAT!
4. wa feet afetarerdt casa ar wees crear ae ara & fares aaa A ae Ue, TTA aT
mente, cad agelt ar qfaieae wer fare aeery BH Say HAT FTA TA UST TA HY VAT UST
. haere ofa & aaqcre oe gat afaarard css F aes ofa are SAT HF TIT Het FH
warsrarey etre HT FAT ATT: aS TART AST Ta Mes TA BH Sage FH ATT HAT, Bray fa .
Wees STI FA FAL UST H Uses ara Sl, H TST H ATT ALA FH IITA HOT Aer TH FF Ts
; Re sorat ar wary Pear sat &, cares ara erated asa F vada ae & srevat va aah art ay & fart seat aaett Tenet ar areas 31
5. tars 3 ae 4 Saeet F re ew ft tors 3 saat 4H yararay Peet dfaararat asa are eaters Pear Tea Tat Sat arse HF Peet are Shr F arose wet Se stray Sat wT
Ta THR CaS BH HTT Sa UST FH Hat F seta Peet cares ara BH wales HE oe set
A areaft | gas aervar, rare 3 saarar 4-H vara fat aerardt css art edt Pau aT
war aa HT TA Usa A Gat afaararé css F spat F seta Ta Uses ATs BT WatsT ATE
orafterar vat arth
6. feat afaarerd asa % csred ara & arecaea, deat aya ais F daa F arfarst at
Hay SA UST H Arareral aay werahrs Fras H aA AAT ATT! ga Aes TUT TS
wal & fraar oet gat afaarard use & feet araraa aaa vera fara a ager tet ardarel & fore farett srterare Br PT BAT AIST VATA LAT ATTA TAT
7. wet tras 3 aera 4 & cea feet afaerard asa arr sacra Feu aa aera feet aay at paaifeafad ase F cafe cee are ar gat afaerart asa a ager Het she VT
ara & eat daft cased erat at Prafefes Fate A aaa B area: .
#) rare 3 & stent aqda & area , senitfeatea cee ar ae Utes ara TT
oF Sa Usa ara H aaa vada 2 aie Da ooh are 2a 38 TH se aa oe oe
| @) 9 home 4} sents ade a, ee Rafe oe } ces aa ad .
Fae Usa ATA Hr HF Ged Tah aaah atfoaa Het F Ieeg A AAT H SIT Hea
| é .
| yaaifeatedt cer ar sere wifes se aor st gat cesT haere welt at aca afarghtd ao att gat use & faneg ae saatfeafad cer avy aqce at ar at areafig
HUTT AT PHL eT ATT {
8. get areata Pet ft sade ar at arat A a feet oft afeerarét asa a frafefed &
fore ATTA ANY HAT TEL ATTAT SATU
e) 0 ose dfaararét ase azar gar afaarerdt ose & arpa att serrate yar > b,
TaTT VATA SIT AAT: =.
. @) Wa sore He TT are A (ase fers) & faa at; -

22° THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]

7) «- Aersay Wars Hear ale gar aaararét css A aH BAT HAT TarrafarsH TAT F

Hata Sreres seat sear Aer, Sar At ara Bt, F at aahaa Sarat ar a far sr; :

a) sa areal A aera yer wer Wel sa ase ® feu serafas ater zat

afaarart usa sre saya Pau at are ATH S ETS ST S aaa ST

HTB - 29
arat ar aftr

1. Fa wor sh soda feet oft feats F ws afaarerd ass at ax ater aaa aad 4
aafere cat caesht arqat ws Sorat & saad at Ht ary Hea F set TT
2. ea ates HAT Te aca Sl alsac He Car ates (fat aS F fra) a cs afaarart usa ar fara @ sar ot gaze afsarardt css SF Ay ITA HAT | SA HEH AAT ATA Hr WA
arr ot feet afaarerét asa & Frarfeat a ast fer ara g afe ta Pare agar ore Frarett z, sata tars 2 H oftarfta f az a arat at ya west & fore a Sere Ft Hea oat Ft TT
ard Bll
3. feet aferereré asa ar are Fart ast feet fadta ad & feo agar ya eats erm afe tat fraret Frafetea Ft are war ST:

am) Acar wat; azaT

@) aat afaararét asat a & fet os a fhe are are, ae i) ae Meet Ft Her Avht ca aad H tears 6 A fAfee areca ore ters TTT
qatag & att sat Fafa eo a os aaa we 4 afte aro we eis CHT A ara far ara &, Arar ii) arcdt F Meet at aaa ale aeat yea aT we A ae 50 ofaaa oe feet ws afaararst usa % wa aya gaa afaa ofa ar yee So a aya ayaa wa A ava fat Ht afaarart sa & fra wert F ateq oqftnat ar HH a HH 50 ohtara Hr AAT ale HAaT Mex .
yea aya fea anft caries a, at fart wae afaararh asa % we aaa gaa afere afeeat &
TAIT Aya Wreaaar cafes F Sl, TAT .
7) «ote afters aver ooftat a area, rae am a aa 50 sited aaa saa af feaartt frat wa aftararét asa & wa serat saat afer oafeeat & carats F at srerar/ Peat aT
afeartaret asa F aeq operat arc fafa Heot F. seer aaa ale ar aa a wa 50 ofa azar wat ar yer ayer easntt carftre| at ot Pest wa afaararét casa Buy aaa WH
ate orfeat & WeaeaaaT Aaa Wereraay cartaea H ST ; eTAT
4) «ale War ware sear aaa Hey He Be Wa AT Fras Hae SH stat Fa feet AT
wa afaararet Usa H AAT WT ZI

aad fe sate oaferat at pare arat ar afeare ora aet er ate wares ad Fa Peet safes Ft 50 vftera a ates aa arg oa arfeeat at ser Ft ord 2 aaa ae oes aT eT
FAA HIT STS Hay srt & Mt Sa Hara F ea aS aa Fa Peet ws aera asa
Fraret vet 2 st ga were FH fre ae aT FH vata cafe & Para wee F ca vara wert far art ae e (Weed SAH Aaa ava areafas areata H aretare & few arareraar

P Cart lave 3(ii)J TG Hl USITa : ARTA 23
agra er a fear war (et aa We) aaa aa farts aesarat 2a Pett ta Fs eartt
EIT, TT atat HS Peet ws dfeararét casa F fea st, FH arctare Beare Cras FH TATA
ac At weft as afte vet ert)!

4. tors 1 A 2 H Bada aT Ae SPT aa ws Afaarars Tea HT ate Pare gat tsa F
ora At we ara At we FH Aaa A Hae arat F few ara |r, ale ah ahs wa a Para aT
H Pear Aaa | (Fas H Broo Frarheat eq Prae aet qaqa SpaeayT He H HITaIe aA fay arlart, wa aH fe a afafatear afr, fh azar vftata aad afafatear a et) site qae afaararét asat & wre At 1s aT Sa alae Hae F ora At TE Sl aay yraihits a Ax ae
Prardt Ua ara Fr Wa HLA Aq Sa HEE FT ArT at F ATS sla ZI
5. wa dftararet asa ar ate fraret at gam ate eu ot Hare F arat Br Ae Pa STAT
afe gat afaararét casa ar aera orfeeardt ae atta acar & fe te oats ar dears aaa
HTS AIST ATTA TAT SAH Tareas Ft ocaeaT Sa Hae H ATH HT OTs HA FH SAH TT
Wasa HF BTS WH A STI
6. Sa Aas TATA "ATTA TT ete WRT" HT TTS:
a) aca H, Bre ete CHS ra edhe acare art sofas afar (fafaaaa) afeftan, 1956 Ft aver 4 & aga Areaar ct wet aT:
a) serg aves Tey H, fe atear = atetita S alefafear ate fe steer sersethrat S
Fare WAT; aT
TT) Bre Hea eet WHT fara sere ores ca aaqeae HVAT Sq Aes Sa FH fore
FEAT et el
7. wa aqeae F aahtea feat At ara & era eu, feet At oaks at ga Here FH ATA Jos AT
afaart wet Sen, aie sae Hears Sa vat rater few au et fra yaa sees aya WE
Soest HA SES UH Sa Het HT ATS HAT SI A VT AE HLT ATT Bla EI
wToaE - 30
cst ert & acer ud ataeht Te aa wee Ht feet ara & stacersta arr F ararea Pasi & sarta steer fase Hert F
sraat % senta corer ert srrat ataelt afteieat & ezeat ® Seite Pasrarftrearct az Hrs ware et TSAI
ATPAE - 34
77a eT
1. afeararét tsa sa Hae Al AT Hes & fore aaah aay & stevia srafera wharsit wr qr aa haa H cra ara a ferfaa ws F wes gat a afrahag SUM
2. Fe RI ea Hesse F Soars 1 H sfeataa afdeaarat Ft aad arta & 60 fer F are
Tae eT
3. ga wee H Saaet Hr fe waa Sr :-
*) «area,

- we THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
i) ra Saree ad Hae Hee aT Sha Fa aa Hae aH Ie ATE Ht Geet arta al HAaT SAH ATS aeeER Sta ava Pet faxfta ae & fare ora A WE a FT ; ii) sa aah aaa a va Hever a aa aad ag rah Hare aT eT, FIT
are & yan fea at aaa sae are fat facta ae & aif fea at car aT eT
@) sea, |
i) ra Faee ae Hag were ay Sha 2 Sas aaah Heese aT FH ade Ae FT ect ata al TAT SAH ATS ae Sra are Pret facia ae & fore wre Ft we ars | Sater F ; ii) Sa ater F a ve avec aE ore aga ae ras He aT lat @, F ah ave & yan fea Ht aaa Sas are Peet farts ae & aif fea at car aT eT |
ATPASE - 32
wart

ae Fuk stars Aas TH AT Te a oH PH fet aaararh ase are ea TATA At ax fear ara | arat Ha are oft afaeraré css ga Hae H aT aA A TAs B a Ts a
A vafe gh aa F are qe at area Pet Havet at AM ah A aH A aH aE AEM Tet aaa arrest & area ar arise Bae HU FT TATA HL THAT z | Oat feafs F ae Hee Fa dae H Porat et area t
*) aad, i) ra Saesz ad Baars wr ae fear oer 2 Sas aT af Herez aS FT eT
aia at azar sae are Pact faxita ad & ora Ft we ora FH Ser ; sz ii) saath dae F fra ve dervec aed & faa aie fear ore @, F Tet Hae Hervsz av % aie are & yan fea at aaa sae are fact fae aed & afta fea at car Tar eT; aq) yeaa, i) fa Saver at F wares Ar fea fear eZ Sas aT aad Faw = ad H aaa are & yam fea at ea Sa are Pet oft facia ad F ora Ht Ee ars F aT, ST
ii) sa Oot ae Fe oe Herve ae & rae afer fear arat & F ort aga Hervet ag & aad are & ere fea at tara cas are Peet facta ae & sift fea at car rer ST

frame aren F, cae feu fafaaa wa a wrfapea aatgecrahtat + ga HTS 4c BEATA
Far @

at eft Fad F gone wares & Praeax ae & area fa AA, feet cs AST soa F
a-at qa ofa F ers Pear war site ait ore aaa wT SF oars fh ret Fresco & Pera Ft feat F sash are waret Arar Sea

: (am [1-@re 3(ii)] ORG Fl UATA : ARTE 25
Ica WTS FT seg ahtics worst
AHI Ht HT cae AT AT A
(wa. at. siteft) (tse hz)
Hara Tees AC as waa wrarearet ae Ue Got oe Het H Aaa AF Stet Hara & after ws Tes BTA HT Ta F fer
Ae Wess sie Tera Steet Tres FH Fhs HIT IT AT BETAS HA Fh fre Helteratast
Prafafad sitet 9% Tene EU Ss, Tt Hes afta ST Sit:
| -&e aaa ora @ fH aaqeae 4 (Par) & tras 1 ar afta ares, fat oft oie Ft, assets ate & fata at ary at Fare Sere at fedea woes Ha Aq TZ, Sa TIT
HTAAA F ASX Al HAT |
| wee 8 (Me wa ary ofaga) FH Gat F, ae aaa are 2 fH ahaa Tem, TT
afaeraret usa ar frat @, stacasia ararara Fo area aevat wea arqait & aRaga & fac
Ta Rea FH (Heat F aaa F few Fax aa sea soem afea) wa, Ta-Tara Hayat fee arr ora ara sae sa afferent asa F aca git wa aH Pe Feat Fae aT
afaarardt asa & stax sar feu are 21
Il SqPae 8 (Het ste arg aaga) H eet F ag aaa ara Z FH stares ararara F.
Fea Aa FH SATA VeTa ST A GS Maat ae sare Fl VS Herat sera aA
Fares F WTA ATA He ST A AAT Sy fe & Ta ara FT Bara & fu ataart FF ae a
SATS H Ha H apes 11 (SAT) H ST ay eT ETT
IV ates 8 (Met st arg WRaea) gar wars 13 (Gotta aftars) F Fat F aE
waa ara & fH eas sated fet ara H are ee At oH afaarars asat F eae ara F
ara fea &, ot fate at agra %, wet ara ard asa F eae et 2, set cara Tse OT aT
Ot HT TT BH APTS HT FATT TAT
Vag aaaT WaT & fH aqme 25 (Aa SaaEI) H Staal ar ae ae aét ATT ST
sae gat afaarart use Ft Pet sect & getfeafaa asa FH fea fat cart aearqa *
ara ot He AT Oat az oars F Cea 2 TT PH ae Ft va az G afte 2 saafeatad as Tt
Tt ot wert & arat oe ore art @ ste a AT aes 7 (HMAATe A ATH) Sera 3 F Saat ae ote zl
Vi AqPae 27, LAAT HT aara-Tarst H Aaa H, TE THAT Bra & PH Area, ATTA AAT HAT
Sah Fae HAT ATA HT ANY Hea are waifaat Hara arson PRT FH dae A Teva Aa
ATPae H TIT 1-H Gea wa Ft Ts AAT HT MAT HL AAT FI
3013 GI/13—4

. 26 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]}
Vil Hear 31 (WEA St) F Fae F, Te THAT ara & PH aqese 27 (AAT ST BaTA-TaTA)
F STAY, SA HetvSt at foray Hervsx ay FH He Hare ATY Fla @, BAT aaqadt Peat fara ate aa A TATST att fora aves A, care fore fateaa eo a orfapa aetecaraheat F ca wrerarer 9x serere fant = |
we facet F ad at eorex ware & faeax are & are fea waa, feedt ws ash ararat H at-at qe sfeat & fora fear wat aie aft oe wars &o a aris a1 ae rear
Hf raat Ff feats F sash as vast arar area area WHATS Ft ses ARs RST
AHI Ft BIT AHI Ht HT A
(uaat. stteft) (Ata eZ)
rary Weare HT ATS usa
MINISTRY OF FINANCE
(Department of Revenue)
NOTIFICATION
New Delhi, the 5" July, 2013
. (INCOME-TAX)

S.O. 2081(E).— Whereas, an Agreement between the Government of the Republic of India and the Government of the Oriental Republic of Uruguay for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital was signed in India on the 8" day of September, 2011 (hereinafter referred to as the Agreement);

And whereas, the date of entry into force of the Agreement is the 21" day of June, 2013, being sixty days from the date of the later of the notifications of completion of the procedures as required by the respective laws for entry into force of the Agreement, in accordance with paragraph
2 of Article 31 of the Agreement; .

Now, therefore, in exercise of the powers conferred by section 90 of the Income-tax Act,
1961 (43 of 1961), the Central Government hereby notifies that all the provisions of the Agreement between the Government of the Republic of India and the Government of the Oriental Republic of
Uruguay for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital, as set out in the Annexure hereto, shall be given effect to in the Union of
India with effect from the 1" day of April, 2014.

[Notification No. 53/2013/500/138/2002-FTD-II]
K. RAMALINGAM, Jt. Secy.

coe I ENT oer WT ~ oN
. (am [1-wre 3(ii)] ANd Sl Usa : HATER | 27 |
. AGREEMENT
BETWEEN.
THE GOVERNMENT OF THE REPUBLIC OF INDIA
AND
| THE GOVERNMENT OF THE ORIENTAL REPUBLIC OF URUGUAY '
FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION —
| OF FISCAL EVASION
WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL
The Government of the Republic of India and the Government of the Oriental Republic of
Uruguay, desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital and with a view to promoting economic cooperation between the two countries have agreed as follows:
“ .

; , 28 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
——————EEIy_>—_>_————————————————————— Il i ~= =—>oo——>>>>>—_>>=======_—=_—_=_=[{===*“"
Article |
PERSONS COVERED

This Agreement shall apply to persons who are residents of one or both of the Contracting

States.

Article 2
TAXES COVERED
; I. This Agreement shall apply to taxes on income and on capital 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 shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, 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, as well as taxes on capital appreciation.

3. The existing taxes to which the Agreement shall apply are in particular:

a) in the case of India:

(i) the income tax, including any surcharge thereon; (ii) the wealth tax; (hereinafter referred to as "Indian tax");

b) in the case of Uruguay:

(i) the tax on business income (Impuesto a las Rentas de las Actividades
Econdmicas -IRAE); (ii) the personal income tax (Impuesto a las Rentas de las Personas Fisicas -IRPF); (iii)the non-residents income tax (Impuesto a las Rentas de los No Residentes -
IRNR) ; (iv)the tax for social security assistance (Impuesto de Asistencia a la Seguridad
Social -IASS); and (v) the capital tax (Impuesto al Patrimonio -IP); (hereinafter referred to as “ Uruguayan tax”).

4. The Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the 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 that have been made in their respective taxation laws.

Article 3
GENERAL DEFINITIONS
|. 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

: (am [l—@vs 3(ii)] SR Hl UAT : AAT 29
rights, other rights and jurisdiction, according to the Indian law and in accordance with international law, including the U.N. Convention on the Law of the Sea;

b) the term "Uruguay" means the territory of the Oriental Republic of Uruguay, and when used in a geographical sense includes the airspace, the maritime areas, under
Uruguayan sovereign rights or jurisdiction in accordance with international law and national law;

c) the terms "Contracting State" and "the other Contracting State" mean the Republic of
India or the Oriental Republic of Uruguay as the context requires;

d) the term "petson" 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;

e) the term "company" means any body corporate or any entity that is treated as a body corporate for tax purposes;

f) the term “ enterprise” applies to the carrying on of any business;

g) 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;

h) 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:

(i) in India: the Finance Minister, Government of India, or his authorized representative;

(ii) in Oriental Republic of Uruguay the Ministry of Economy and Finance or its authorized representative.

j) the term "national" means:

(i) any individual possessing the nationality or citizenship 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 Uruguayan 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) The term “fiscal year” means:

i) in the case of India: the financial year beginning on the |*\ day of April; ii) in the case of Uruguay: the calendar year beginning on the 1° day of January for the purposes of individuals and the taxable period of 12 months for other persons.

- 30 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SECc. 3(ii)]
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. ;

Article 4
RESIDENT
1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation, 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 or capital situated therein.
2. Where by reason of the provisions of paragraph 1 an individual is a resident of

. both Contracting States, then his status shall be determined as follows:

a) he shall be deemed to be a resident only of the State in which he has a permanent 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 with which his personal and economic relations are closer (centre of vital 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 shall 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 resident 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 endeavour to settle the question by mutual agreement. —
Article 5
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 wholly or partly carried on.

‘ (art []-wrs 3(ii)] Ra ST USA ; AAT 31
2. The term “permanent establishment” includes especially:
a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop; f) a sales 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 i) amine, an oil or gas well, a quarry or any other place of extraction of natural resources.
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 183 days or more.
(b) he furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, but only where
_ activities of that nature continue ( for the same or connected project) within the country for a period or periods aggregating more than 90 days within any 12-month period.
4. Notwithstanding the preceding provisions of this Article the term “permanent establishment” shall be deemed not to include:

a) the use of facilities solely for the purpose of storage, display of goods or merchandise belonging to the enterprise;

b) the maintenance of a stock of goods or merchandise belonging to the enterprise

solely for the purpose of storage, display;

c) the maintenance of a stock of goods or merchandise belonging to the enterprise

solely for the purpose of processing by another enterprise;

d) the maintenance of a fixed place of business solely for the purpose of

purchasing goods or merchandise or of coliecting inform tion, 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 er auxiliary character;

f) the maintenance of a fixed place of business solely “or 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 prenaratorv — or auviliary 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

gran THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
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’ te.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 plate 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 regularly delivers goods or merchandise on behalf of the enterprise;

c) habitually secures orders in the first-mentioned State, wholly or almost wholly for the enterprise itself.

6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a
Contracting State shall, except in regard to re-insurance, be deemed to have a permanent establishment in the other Contracting State if it collects premiums in the territory of that other
State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies.

ce 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 on behalf of that enterprise, he will not be considered an agent of an independent status within the meaning of this paragraph.

8. 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 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.
Article 6
INCOME FROM IMMOVABLE PROPERTY

1. Income derived by a resident of a Contracting State from immovable property situated in the other Contracting State may be taxed in tha: other State.

2. The term “immovable property” shall have the meaning which it has pader the law of the Contracting State in which the property in question .s situated. The term shall in any case include property accessory to immovable property, livestock and 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

- (am —wrs 3(ii)] Ud Fl UTA : SATERT 33
. the working of, or the right to work, mineral deposits, sources and other natural resources; ships, boats and aircrafts shall not be regarded as immovable

property.

3h 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 for the performance of independent personal services.

Article 7
BUSINESS PROFITS

i. 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 enterprise 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.

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.

4. In so far 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 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. Kor 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.
3013 Gi/13—-5

34 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC, 3(ii)]
aa_aaa—_—____—_—_—_—_—_—_—_—>>>=>>——o— II ————>—>—=—=———[=SS—==—= S
: 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 Article.
Article 8
* 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. If the 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. The provisions of paragraph | shall also apply to profits from the participation in a pool, a joint business or an international operating agency.

Article 9
ASSOCIATED ENTERPRISES
1. Where a) an enterprise of a Contracting State participates directly or indirectly in the inanagement, 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, 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 the 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.

3. The provisions of paragraph 2 shall not apply where judicial, administrative or other legal proceedings have resulted in a final ruling that by actions giving rise

- L-wt Il-are 3(ii)] UNA Hl UAVA > AAT 35
tv au adjustment of profits under paragraph 1, one of the enterprises concerned is liable to penaity with respect to fraud, gross negligence or wilful default.

Article 10
DIVIDENDS

1. Dividends paid by a company which is a resident of a Contracting State to a

resident of the other Contracting State may be taxed in that other State.
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 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 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 | and 2 shall 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. Jn such case the provisions of Article
7 or Article 14, as the case may be, shall apply.

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 the dividends paid by the company, except insofar as such dividends are paid to a resident of that other State or insofar 2s the holding 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
7 oo
1. 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

- 36 THE GAZETTE OF [INDIA : EXTRAORDINARY [PART II—SEc. 3(i1)] .
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, the Export-[mport bank of India,
: the National Housing bank; and :
(ii) in the casc of Uruguay, Banco Central del Uruguay, Banco de Ja Republica Oriental del Uruguay, Banco Hipotecario del Uruguay; or
_ , c) any other institution as may be agreed upon from time to time between the
Competent authorities of the Contracting States .hrough exchange of letters.
4. The term "interest" as used in this Artic! 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 late payment shall not be regarded as interest for the purpose of this
Article.
‘ 5. The provisions of paragraphs | 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 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. ’
, 6. Interest shall be deemed to arise in a Contracting State when the paycr is a resident 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.
7. 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, havi: 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

; [art 1 -aue 3(ii)] RA S TSTA : TATIRTT 37

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 laws 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 cinematograph 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.

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 that State itself, a political sub-division, a local authority, or 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.

(b) Where under sub-paragraph (a) royalties or fees for technical services do not 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 shall 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

- 38 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
royaities or fees for technical services, having regard to the use, right or information fer 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 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 13 .
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 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 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 or aircraft shall be taxable 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.

6. Gains froia 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.

Article 14
INDEPENDENT PERSONAL SERVICES

1. 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 shall be taxable only in that 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

4 Lu li-@re 3(ii) J AG Hl TATA: AAU 39
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; 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, lawyers,

engineers, architects, surgeons, dentists and accountants.

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 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.

Article 16
DIRECTORS' FEES
Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other
Contracting State may be taxed in that other State.
Article 17
ARTISTES AND SPORTSPERSONS

A0 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident 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 personal activities as such exercised in the other Contracting State, may be taxed

in that other 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 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 local 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
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 shall be taxable only in that State.
Article 19
GOVERNMENT SERVICE
I. 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, 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 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 pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.

° (art I]—ere 3(ii)) UNA Hl UStTa : ATT ab
3. The provisions of Articles 15, 16, 17 and 18 shail apply 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 subdivision or a local authority thereof.
Article 20
PROFESSORS, TEACHERS AND RESEARCH SCHOLARS
1. A professor, teacher or research scholar who is or was a resident of the
Contracting State immediately before visiting the other Contracting State for th«
purpose of teaching or engaging in research, or both, at a university, college 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 for a period not exceeding 2 years from the date of his first arrival in that oth r
State.
2. This Article shall apply to income from research only if such research is undertaken by the individual in the public interest and not primarily for the benefit of some private person or persons.
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.
Article 21
STUDENTS

1. A student who is or was a resident of one of the Contracting States immediately before visiting the other Contracting State an who is present in that other
Contracting State solely for the purpose of his edi:cation or training, shall besides grants 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 training; 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.

2. The benefits of this Article shall extend only for such period of time as may be reasonable 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 ar-ival for the purposes of his education or training in that other State

3013 GI/13—6

- 42 THE GAZETTE OF INDIA : EXTRAORDINARY {PART II-—SEC. 3(it)]
Article 22

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 | shali 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 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, shali apply.

5. Notwithstaading the provisions of paragraphs | and 2, items of income of a resiteni of a Contracting State not dealt with in the foregoing articles of this
Agreement and arising in the other Contracting State may atso be taxed in that other State.

Article 23
TAXATION OF CAPITAL

I. Capital represented by immovable property referred to in Article 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State.
2. Capital represented by 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 by movable property pertaining to a fixed base available to a resident of a Contracting
State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other State.
3 Capital represented by ships and aircraft operated in international traffic and by movable property pertaining to the operation of such ships and aircraft shall be taxable only in the
Contracting State of which the enterprise owning such property is a resident.
4. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.

Article 24
METHODS FOR ELIMINATION OF DOUBLE TAXATION

Double taxation shall be eliminated as follows:
i. in India:
2} Where a resident of India derives income which, in accordance with the provisions of this
Agreement, may be taxed in Uruguay, India shall allow as a deduction from the tax on the
‘income Of that resident, an amount equal to the tax paid in Uruguay.

; [77 I-avs 3(ii)] a SI UA: HATA 43

Such deduction shall not, however, exceed that portion of the tax as computed before the deduction is given, which is attributable to the income which may be taxed in
Uruguay.

b) Where a resident of India owns capital which, in accordance with the provisions of the
Agreement may be taxed in Uruguay, India shall allow cs a deduction from the tax on wealth of that resident an amount equal to the capital tax paid in Uruguay.

Such deduction shall not, however, exceed that portion of the tax as computed before the deduction is given, which is attributable to the capital which may be taxed in Uruguay.

c) Where in accordance with any provision of the Agreement income derived or wealth owned by a resident of India is exempt from tax in India, India may nevertheless, in calculating the amount of tax on the remaining income or wealth of such resident, take into account the exempted income or weaith.

2. In Uruguay:

a) Where a resident of Uruguay derives income which, in accordance with the provisions of this Agreement, may be taxed in India, Uruguay shall allow as a deduction from the tax on fhe income of that resident, an amount equal to the tax paid in India.

Such deduction shall not, however, exceed that portion of the tax as computed before fhe deduction is given, which is attributable to the income which may be taxed in India.
b) Where a resident of Uruguay owns wealth which, in accordance with the provisions of the
Agreement may be taxed in India, Uruguay shall allow as a deduction from the tax on capital of that resident an amount equai to the wealth tax paid in India.
Such deduction shall not, however, exceed that portion of the tax as computed before the deduction is given, which is attributable to the wealth which may be taxed in India.
c) Where in accordance with any provision of the Agreement income derived or capital owned by a resident of Uruguay is exempt from tax in Uruguay, Uruguay may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the
éxempted income or capital.
Article 25
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 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.

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

- 44 THE GAZETTE OF INDIA : EXTRAORDINARY {PART II—SEC. 3(ii)]
Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants 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, fees for technical services 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. Similarly, any debts of an enterprise of a Contracting State to a resident of the other Contracting
State shall, for the purpose of determining the taxable capital of such enterprise,

’ be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State.

4. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shal! not be subjected in the first-mentioned 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, notwithstanding the provisions of Article 2, apply to taxes of every kind and description.

Article 26
MUTUAL AGREEMENT PROCEDURE ,

1. Where a person considers that the actions of one or both of the Contracting
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 States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph | of Article 25, 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.

2. The competent authority shall endeavour, if the objection appears to it 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 notwithstanding any time limits in the domestic law of the Contracting States.

- 3. The competent authorities of the Contracting States shall endeavour to resolve 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

P pom dh a%s 3041) 7 FG Bl USGA: ATENCUy 45
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 27
EXCHANGE OF INFORMATION

1. The competent authorities of the Contracting States shall exchange such information (including documents or certified copies of the documents) as is foreseeably relevant for carrying out the provisions of this Agreement or of the domestic laws concer..ing taxes covered by this Agreement insofar as the taxation thereunder is not contrary to the Agreement. The exchange of information is not restricted by Article 1 and 2.

2. Any information received by a Contracting State shall 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 covered by the Agreement. 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.

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;

c) 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.
5. 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 28
ASSISTANCE IN THE COLLECTION OF TAXES
1. The Contracting States shall lend assistance to each other in the collection of revenue claims.
This assistance is not restricted by Articles | & 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
3013 GI/13—7

46 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
Agreement or any other instrument to which the Contracting States are parties, as well as interest, administrative penalties and costs of collection or conservancy related to such amount.
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.
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 b) 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 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:

° (arm I]-wve 3(ii)] URA Sl USaTs : STATE 47

a) lo 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);

c) 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;

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.

Article 29
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 laws and measures concerning tax avoidance or evasion.
2. Except as otherwise provided in this Article, a person (other than an individual), which is a resident of a Contracting State and which derives income from the other
Contracting State shall be entitled to all the benefits of this Agreement otherwise accorded to residents of a Contracting State only if such a person has the qualifications as defined in paragraph 2 and meets the other conditions of this Agreement for the obtaining of any of such benefits.
3: A person of a contracting state is a qualified person for a fiscal year only if such a person is either:
(a) Governmental entity; or (b) | acompany incorporated in either of the Contracting States, if -
(i) the principal class of its shares is listed on a recognised stock exchange as defined in paragraph 6 of this Article and is regularly traded on one or more recognised stock exchanges, or , (ii) at least 50% of the aggregate vote or value of the shares in the company is owned directly or indirectly by one or more individuals residents of either of the Contracting
States or/and by other persons incorporated in either of the Contracting Ststes, atleast
50% of the aggregate vote or value of the shares or beneficial interest of which is owned directly or indirectly by one or more individuals residents of either of the Contracting
States; or (c) a partnership or association of persons, at least 50% or more of whose beneficial interests is owned by one or more individuals residents of either of the Contracting States or/and by other persons incorporated in either of the Contracting States, at least 50% of the aggregate vote or value of the shares or beneficial interest of which is owned directly or indirectly by one or more individuals residents of either of the Contracting States; or

. 48 THE GAZETTE OF INDIA : EXTRAORDINARY (PART II—SEC. 3(ii)]

(d) Accharitable institution or other tax exempt entity whose main activities are carried on in either of the Contracting States.
Provided that the persons mentioned above will not be entitled to the benefits of the
Agreement if more than 50% of the person’s gross income for the taxable year is paid or payable directly or indirectly to persons who are not residents of either of the Contracting
States in the form of payments that are deductible for the purpose of computation of tax covered by this Agreement in the person’s state of residence (but not including arm’s length payment in the ordinary course of business for services or tangible property and payments in respect of financial obligations to a bank incurred in connection with a transaction entered into with the Permanent Establishment of the bank situated in either of the
Contracting States).

4. The provisions of paragraphs 2 and 3 shall not apply and a resident of a
Contracting State will be entitled to benefits of the Agreement with respect to an item of income derived from the other State, if the person actively carries on business in the State of residence (other than the business of making or managing investments for the resident’s own account unless these activities are banking, insurance or security activities) and the income derived from the other
Contracting States is derived in connection with or is incidental to that business and that resident satisfies the other conditions of this Agreement for the obtaining of such benefits.

5: A resident of a Contracting State shall nevertheless be granted the benefits of the
Agreement if the Competent Authority of the other Contracting State determines that the establishment or acquisition or maintenance of such person and the conduct of its operations did not have as one of its principal purposes the obtaining of benefits under the Agreement. ,
6. For the purposes of this Article the term ‘recognised stock exchange’ means (a) in India, any stock exchange which for the time being is recognized by the central Government under section 4 of the Securities Contracts (Regulation)
: Act, 1956; and (b) in the Oriental Republic of Uruguay, the Bolsa de Valores de Montevideo and the Bolsa Electronica de Valores S.A; and (c) any other stock exchange which the Competent Authorities agree to recognise for the purposes of this Article.
de Notwithstanding anything contained in this Article, a person shall not be entitled to the benefits of this Agreement, if its affairs were arranged in such a manner as if it was the main purpose or one of the main purposes to avoid taxes to which this Agreement applies.
Article 30
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.

¢ (am [lave 3(ii)] RG Hl USIA : AAT 49
Article 31
ENTRY INTO FORCE
|. 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 sixty days after the date of the later of the notifications referred to in paragraph | of this Article
3. The provisions of this Agreement shall have effect:
(a) In India, (i) in respect of income derived in any fiscal year beginning on or after the first day of April next following the calendar year in which the Agreement enters into force; and (ii) in respect of wealth which is held on the last day of any fiscal year on or after the first day of
April next following the calendar year in which the Agreement enters into force; , (b) In Uruguay, (i) in respect of income derived in any fiscal year beginning on or after the first day of January next following the calendar year in which the Agreement enters into force; (ii) in respect of capital which is held on the last day of any fiscal year on or after the first day of
January next following the calendar year in which the Agreement enters into force.
Article 32
TERMINATION
This Agreement shall remain in force indefinitely until terminated by one of the contracting
State. Lither 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 on which the Agreement enters into force. In such event, the Agreement shall cease to have effect:
a) In India, (i) in respect of income derived in any fiscal year on or after the first day of April next following the calendar year in which the notice is given; and (ii) in respect of wealth which is held on the last day of any fiscal year on or after the first day of April next following the calendar year in which the notice is given; b) In Uruguay, (i) in respect of income derived in any fiscal year on or after the first day of January next following the calendar year in which the notice is given; and (ii) in respect of capital which is held on the last day of any fiscal year on or after the first day of January 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 New Delhi this 8 day of September 2011, each in the Hindi,
Spanish and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall prevail.

° 50 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
For the Government of the , For the Government of the
Republic of India Oriental Republic of Uruguay ,
Sd/- Sd/-
( M.C., Joshi) (Cesar Ferrer)
Chairman Ambassador
Central Board of Direct Taxes Embassy of Oriental Republic of
Department of Revenue Uruguay in India
Ministry of Finance
Government of India

7 (am I]—wve 3(ii)] FRA SI USGA : TATE 51
PROTOCOL
At the signing today of the Agreement between the Republic of India and the
Oriental Republic of Uruguay for the Avoidance of Double Taxation and the prevention of Fiscal Evasion with respect to Taxes on Income and on Capital, the undersigned have agreed upon the following provisions, which shall form an integral part of the Agreement:

I. It is understood that the last sentence of paragraph 1 of Article 4 (Resident) does not exclude from the scope of this agreement, any person who is liable to tax, in the Oriental Republic of Uruguay by virtue of the application of the principle of territorial source.

II. With reference to Article 8(Shipping and Air Transport), it is understood that, profits derived by a transportation enterprise which is a resident of a Contracting
State from the use, maintenance, or rental of containers (including trailers and other equipment for the transport of containers) used for the transport of goods or merchandise in international traffic shall be taxable only in that Contracting
State unless the containers are used solely within the other contracting State.

III. With reference to Article 8 (Shipping and Air Transport), it is understood that, 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 (Interest) shall not apply in relation to such interest.

IV. With reference to Article 8 (Shipping and Air Transport) and Article 13(Capital gains), it is understood that notwithstanding anything contained therein read with the domestic law of the Contracting States lead to a situation where an income is not taxable in the resident State, the source State shall retain the right to tax such income. ,

V. It is understood that the provisions of Article 25 (Non-discrimination) shall not be construed as preventing a Contracting State from charging the profits of a permanent establishment which a company of other Contracting State has in the first mentioned State at a rate of tax which is higher than that imposed on the profits of a similar company of that first mentioned State, nor as being in conflict with the provisions of paragraph 3 of Article 7 (Business Profits).

VI. With reference to Article 27 on Exchange of Information, it is understood that
India may share the information received under paragraph | of that Article from
Uruguay in respect of a resident of India, with other law enforcement agencies of
Government of India or its Parliament.

VII. With reference to Article 31 (Entry into Force), it is understood that the provisions of
Article 27 (Exchange of Information) shall have effect, relating to any fiscal year, next following the calendar year in which the Agreement enters into force.

“59 THE GAZETTE OF INDIA : EXTRAORDINARY [Part II—SEC. 3(ii)]
IN WITNESS WHEREOF, the undersigned, being duly authorized by their respective
Governments, have signed this Protocol.

Done in duplicate at New Delhi, this 8" day of September , 2011, in the English, Spanish and
Hindi languages, all texts equally authentic. In case of divergence between the texts, the English text shall prevail.
For the Government of the For the Government of the
Republic of India Oriental Republic of Uruguay
Sd/- Sd/-
( M.C. Joshi) (Cesar Ferrer)
Chairman Ambassador
Central Board of Direct Taxes Embassy of Oriental Republic of
Department of Revenue Uruguay in India
Ministry of Finance
Government of India
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