Notification No. 23/2014 [F.No.503/8/2005-FTD-II] / SO 956(E)

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Use Wo lo Ueo-33004/99 REGD. NO. D. L.-33004/99
Fant vp
Hai |
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Che Gazette of India -
ATA
EXTRAORDINARY
wrt []—avs 3—3U-Wy (ii)
PART II—Section 3—Sub-section (ii)
wiftvenre & warnfera
PUBLISHED BY AUTHORITY
a. 793} ag feeeh, yprenz, ard 28, 2014/8 7, 1936
. No. 793] NEW DELHI, FRIDAY, MARCH 28, 2014/CHAITRA 7, 1936 oo.
faer warea (<rerex fae)
aftrrar awe facet, 28 ard, 2014 .
(arree)
FT. 3T,956(H1).— SPs ara ae HAH Seer F alee Heresy F Ree wa PAedhr aoe Bt Cees] few arr
Torrey A aeent she Straits warsrarét worerer stern At acare & dhe sary Hare (Pra eae ara M A VU eT
wre), fre az ve Peet FH 22 serach, 2013 Hr Aearare Pe me Y, 22 aeqar, 2013 & wart Shr Gt fH sagaT
AU wy ayes 30% aqare, H A oT ary Her} fy aaa Vat} erat F aver gar Haferr chard TS ay
& are aftepearatt F & are Ft athtepra Ht arte zi gafan, wa arrax afafrra, 1961 (1964 ar 43) Ft arer 90 ere vaca efeerat er wah He EU, AT
acart wager afrgire wet FP aH ars sors SH AU UH sree area ae F arH 1 whe, 2014 F ary ait
[afar #. 23 /2014/ "51.4.503/8/2005-f3.%.9.-11]
1406 Gl/2014 (1)

2 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)} )
awe
OT YC wet H cater Stet Herars & aftere atc creer rary By Crt & ferq .
WT TTT FY ATT
a
. — Rwerifinw eerrorerrdt fteter srorcree Ft aecere fe dente Hae sree rover she stteaifires araroardt fist arorerea, are oe wet dar F age aera] aR ake crores erate SY Shwk Fe sar Tat eet dhe ars agaty St aprar BA BP & cH Hex sca aay FF
wear e, fenqarc were ECs: |
aaa - 1
arrfiter safer ae ee Tr satay Ie ATT ST, WY Harare creat FF Pet cH sear aat F Paret F
TITRA - 2 |
afeafera #z .
1. we were fied afererh ove arr yaw Cortes se-wart aren carte wfc are are Te BATT Te He sae F ary er, wy F feet ot ag a erry TT
| 2. we are reer seater % starcor B re aferat ae ae ae wet she Seat are wae as Tear Aaat Ft Her arfarat 7x wet eee per sre Te serat ara meat Te ATT Te ae wT eT IT eA ae ee eT HAT TTC
| t
3. fore athe weet re ae we aT RT, F ea THT g-
FR) are, rere rae ger re operat are arferare st orf f; (fart gee are “aredty ec" HET TTT) | |
(q) Steer, arerae ret ter He are arate orca sereit atatax oe are sree Ht errfBteT a:
(Pre wets are “sfterer ae" HET ITT); _
4, ag were Piet At aeret aera were: wart HE TT At aT RPT HY HET AT Perez fier wa Ft atte oO , ware fret wet & softer sera sah erry Te ATE aT | afterere creat & mere orfererd fg ot agent afadat & tater F ew Tae ar afer re wor oY TAH oes HET MTT F Fae re eT
TTA - 3
ararer oftarand
1. TH Re} ars re ow set A aera Tae a a: , (=) “area” erex & RTT B - ATT eT TTA tt cat cerethe aye she sa wax & arquedte aa afafter ere ft ser agit ar nite & ert aq aoe ox dae ug de & afer afee adie
. 2 PRT wer areehte ange & arqare area weyeer aera ohare, ser afters war darherare F; (3) “sitter” oree & ante & sthreties warardl fear sores, frat sear yh cree araftr wer ate erty aye Sah STC HT RTe Se Tar fate afte as she aardhie den ite F wer sacashe arg ate rah ode Perr & ayes abaaies warrardl freee wera ar wear wear aferars,, .
erarhirere & array am are BY eer F; a,

"Crm Ilene 3(ii) J SNA HT USA: STITT _ 3
(7) ora afterer& cea” sar “geet asferark cee” eredt at anh ded A ateqare aver woTST sea areas aarorerét stata wrorerea #:
(a) “ore” orex ve F arg aafe, re aod, aofeat A are der ake HE aa ae afte & re safe afaarerd cedt F va Heart argat FH aee UH HTT wag HBT FH aaa wa Z; (s.) 0 “meet” erew & are forfre Frere aorar are wer afte & fra we carat & fare wa faite Pre .
Be F ATA WAT
; (a) “weret” orew fineh vane 3 archer Hr HA IT ATT SPT;
. (a) “ww afrerer& asa a7 gers" wor “gat dfaerard aeg wT yee" weal & wre: wa dared wad fardt fraredt aren aarferr wre ger cet gat afterer& ase & fat frardt ara darter ere cere afte &, (a) “atercergtr ararara” erect & after & - wa aera cree & Pet gern aver oftarite Pet ora a aren arqard arr aRaea & & are sa feat % wa Hears seAT aaa Hae Fat afararé Ter carat & afte ft aerar wre BT; (H) “were urftrerdt” sree & afte f:
(i) are srorerea ara H, fee vet, area aeare sera Serer ore wha Pe; (ii) fterer % : sia Per crores wgr-arger (m) “aften” rex & are g :
(i) Pret we aftarerdt cee A ofbwer arco Het aver HE SrA;
- (ii) Vk Faw eafRs, efter ste seer, FRR ara a eg A Afra Pet eevee ree Hp TTT A
are erat Bt, .
(2) cme? grea & dad H aqare ered we ara SHAT we ae &, Tog sae Ret AE coer entre at
0 gah, oh war wet cane fest ger ora gw det F Aa Hy, Pre oe ag HOT aT ST BD eM
wet & tee F are me ate Sera RTA BT ATH ST
(3) “crore ak” erez 8 oer fe |
(i) area rorerse HATA H, gett ater St ares BA ater Paes ae, (ii) ftetar area F : ett ater Ft ater BMF ara a Prater ae
2. feet cree are rat ar Fine oft er ear were A rn oe aT er 8, oe oH eB se |
arte a &t, erst rarer Pre sree sor at ar har at ser wet Be sata Fare ge Toe, fre Te Te TTT AT
dra 8, argit Be tanta er errr her ah ag oe ser ree Hay Fae aA Ta we TTT skanky aT A art we wart Bhar oY sa ed & ae art & stefe eorrg ard F |
aoa ~ 4 :
Pravett .
1. Be HOt varart “wa aera ase a ard’ ve ar at Pedt Wa af a B fire oe va HF
(art stent cer after, rare, ware-eare, Parra eave aera Pret Qe et reer ae aaa oT AHA e te gait ae cer ate rea AE Coram Sera aera SAT carter ere ft amber Si Tae, gee A TE |
Tar safer arfirer ag Spar Pra oe Heer se cree H faa atat F ar arat ara ae va TTF aC TAT aT eT EL a

4- + THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
2. wet tears 1 saaet H wre, WE ais Aa A afarerd cay aH ard w, zat seh sae frarqarc aa Ft amet :

(=) 0 - oe ee set ce oF Pare ara oe Ha TA oH ear Prava-qq saeer BF, afe za arat FF
areat Fae cart Parag soerer wy, at ag Se TT er oH Rardt ara orem, Pra are va anktrre afc arfttes caer uftaax & (AgerIet at sr Hr) ;

(a) 9 af sa ose an, Prad vam ageret fee Afza ¥, Peer ae Pear a7 eer BF aren fe seer art crvat Fa fet ft cree F ats earct Pare-qg sree vet gt, at ae sa ave aT om Pare .
BAT OTT Free AE STRAT TENT BT; .

(t)' af ag areca Art H aeet F cer a aa sas B feet Ht cee F ae cer BH, A ag Va THT
Soap Parelt rary area fPrerer fe ag eH TAB |

(3) afte ag cat et creat ar afew a aera sat & feet Ht cee or afew ae Eat afterard ot

Reem arftrardt orcecfos agaft are gar weer ar frtehe BE
3. swat ee oqeeee & eras 1] erat & are fet ons & few arg antes Stat afaareré avai wr Part
W, a 38 Hee sa TET He ard ar wre Pret sear wart water ears fea 21 ahs se cee a Pater at firey oT emer et fPreret Serer vast water carey fers & at aftarer& creat & aera orftrarh orcectts agale & ve |
WMT HT TATE BCA HT TATT HUT |

age - 5 |
1. Te were vata & fare “eat Mearey” ve FT arene HTehare & va Mfhara cara & B, Free aver Fret ,
| em ar wrerare MeN: array ster: Fra TET ei
2. earl dearest a Ff Patera Paes ofita eit :

(®) vatert wr YE ear; a a (re arra; | _
ae raters, | | |

(0 Stier; on

(§) are artercr; _ |

(3) wa, Awa te ar Fat, were 7 ae Gat & Pend} aT eas; 7

(a) 0S Se, are area AE eg eT GT BT, TAA, aera arora eater wea AARat A og,

() ere feet ar ere; . |
© (et) re wafer aE reer, Git gaa a esr eft year ETAT eh | |
3.( ) are wear-ere sear Prater, wearer area etter Peron sera war FRART Rear arerar get afer eet i

artqary at wy caret deareay war ae tar waa ere, ara sear wrtaery 183 feat & afte cae _

TH ae |
(eq) dart eq wor, Pratt ee wat Re germ Hat ge aberfedt away sree anftiet arerr & se see A -

-reraeff tart ante &, Beret cw eat dearer 8 Tog hee wet Serer cer} ater oe eT oo

; en oo lei

- [AM 4s 3(ii) ] UR AT USAIA : STATI 5
frarererre fret 12 ade Ft aah & sftax Her Raraz 90 fea a afte A aafe ar sraferat & fw wré
cect at (set arerer ae oa TAT eq);
4, ge aqua h pda cadet BAS ge ot eat dears ve f Pee a anita ag weer ore 7
(=) ga gaa & dafte are seer eager & are awercr aaat veda & watered yfaerat a i) are vere array washer Ye eater gern & ahaa are aay gor geqatt Alt ete aT ce:
THTT BT, .
(1) Pret rer Sera are Heer aarfire Py ort sata Tere F ae aeaT Wwa-aeqat Beets HT
TH-TATA FLAT; (3) sere fora are eer we -reqal a haa wa Ber AT ea Gar THT Hea |} fe area fart fafdae cart FT Ce-Cara BHAT; a (s.) sere % fare Hae aren sear eras caee & Pet wer ardHere Ht wars wahrard Hrerayre
. fore Fafdae Cay HT CECA RAT
(a) ss sa-ferars (%) & (8) wn F sfeatea sae Pet ard-nerct F aarerrt & few errara & fat
Piftea cart aT cetera eT, aad PH ee dato B ofreaeg arta & ART AO TT
errer erterare Pret orefan aT aerTs TET FT BT
5. eran 1 he 2 oraelt ae ge a, et eats Afra feet awe, Are ge eras 7 ay eter a, _
& Fira ae safe ae eftarerd roe & fet sere Ft ate 8 we aftererd cor F ard wear &, Tet oT Aina .
% ade F, fey se sat ser & fe weer 8, wanafas aererd ase FH va gar % eet dears aT BT
rar eT, af Re aaRe | = 7 -
| (*) Sa sere are 3 get cree H SP aor wy er ele re at ate ag area ge Ife |
ware At wear Bt, ore ae fe Ue oafes Ft afahehiat Acars 4 sfeafaa or afefahat we
Sifter a at, Pare aPR ag ardrare a Us AfPaa eae F seat B, at ga toms & aaa B attr a wrcrart & ga fafoaa carr Bt wa are wearers Tet TATA; aeTAT , (ex) Rar AE efter wre at a, fle ae Poe at near veneer Ter AY are aeAT Tee aeqat ar cate caer at frat & ag vers A ate B ae eeraT qwy-geqat Ht Praha wa a feettae:
; HCA Bt, AAT co, -
(7) ere, Ten few pen saa ara Paar wafeaea Use Fareed As wT ase WA HAT
@ aaa sean war Zat seat & fac ot Prsrard Z ¥ ava faa 3, woe set ara. .
Prarorefty %, War ag sary, . oo
6. ae aqua & oF wraeret H ete gy ot, dfeerarh csr ar Star sere st ga: Str} eed TTA, TAL
aftararé asa F card dearest cant ara ore, afe F va gat ase} Aa F After cat wer 3% aaa ea
Feafe & feet uate & Pret we satte arerer & sae fore athe ar star aca @, ret eas 7 aT RATS
7. > fart vere ar fast aftererd csa.F are ga arom & fat earl dears er BT ae. ara OTT FH AE
| ga cree H faett are, ararer afters wae array eas Afra are Pelt are ake Be eTeaT.a dare War 8, ah FR RR safe ara aadtarec ase She sor He ET Teh, eR Ae ate erie a: snTaT
146 od]iy-z | re

6 ° THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
aren obese sere ate} Per ont gt, a ea xe fers & aftrory B siete eres fee ar ae at are

are |

8. we wen fH are aeeeft, at oH afaarerdt csr Ft fraret &, feet tet werdt ar are acct & gee fat

det acest gre frahre act 2%, ot get dfaarerd ase Ft frardt & aera HT va gRt TT F (ae fat et

aearrg & arere S eeaT Hera) Hrcrare weet B, at sa Set HS Pet cH Herth wr eae: A art wT amt
SEAT FET ATAT ATCT |

aye - 6 .
are Mea F are

1. wa afeerered trey h fret rare ere gat afearard ove F flea wae aeahy F ora ara ax Ta FAY
afteraré cea F He Tay ATTA

2. rae weary ve ar at agt ger ot sa aftererd asy & eq & aeta vem at ¢, Pred frarenity

aeate fara & 1 ver re H, fart oft gree, & arftrer att - raze aeahe & serena & ea arahy, Bhs athe arith

H oae qe oe svenc, 0 aftrerc irr ox qearahe aaet ararea egy Sede ary Be et, eee arse :
ary 3 aftrarc afte ert wey afer eee F afte ate Adee qrars & afters sera ert wey afirarz,

aftr vere, ate war ser orphtes care, wears, Aart she arava are aT we Fave ay oT

3. derars 1 sede, ave aeahe % vert sear, ga Prat oe 8 gear cam fet aq were & yar &

TeAT Or are area ae At ATT gi .

4. torars 1 atx 3 oadu, fart sere Ft sere areata 8 ore are ox ae ears Safer Ararat H ferred F
fare weer oer aeahe F ore are ae At aT Bit | |

agen - 7 ‘

. | wreare FT ATT

1. wa aftarere crea & fedt sere ovat oe Hare Tet Tee F HT aa are We ae fH ag TaM gat efererenr eh cree fee fart earth aeons % aver S Se TET a MATT eT HTT a | AA Te sam Sate To .
& erdare Hea W AY Fa TIA ara Te Far Ter F ft He STAT oT aT 8, Peg sah rat Beer gay ster

Tee wee TT OT Te RITA Hea TT HY TA ET ATT TTT . |
2. fears 3% seat ® after Cee Eu, wat ww afdarers cee a HE ge Gat afaarert ae H fear fart cart sears H areca & arcane HAT BT, Tel eH Saararc ces F Va ears Fears F Srey BU aH, F -
ara art adr rv era Ft erat aa anit we TH TATA aT Vae Praet-qeat oheafaat F ws wars ar fraa- -
ae arfrerat F aa ger HE she ffsre vers star ate ay Va vers ara Yora: cada ST A Hat HEMT F

ferret ag oH card dearest ZI °
3. Paeft cori dearest & arat & Paton wer a sa oat Ht wetet At agate tt ores, ot se eared dearest

% yarraré est far ore &, Brad ca vere fo we artaré es areas werafts og ot ofits #, va Ht a sa _
ure % fax re ef Pret earet dearae fea & reer Pat ove Howe erga B sede & aqarc gar dha |
arenrefag rear Fly ae gt meh, xrfreet Bs ater HH, fe ae a, ee Freht meteht ot agate et Soh att Pare eet '
dearer ener sere yer erate arear ak fet wer avatars at Me, aeeret sear wer afterd & vit

wee crafted, Heat sear ser ware aera H aera a sear Falke Reories tareit evar vert Fe fire alter

Wray wey Tare & wite sear shar seat & arrat & afar cart terres a sare Au we wa at sare HBT i.
% war (areata orat A ofaght e wis afahtea) A we a edt vere, Ae cart dearer are Ret, are :

ara sey afer & wart & fre aaa seh ser arateat st aerar Pened fats Aart aera weer % faq

wafers ar ater warel arer weet F crafeeat, Htat aerar eer eet ware At erahtay & arer Pet gee H Qerrere

" [apr we 3(ii) J Ra FT UAT : TATE . 7
Sr array Pht Mfr sere ares BH afaoee fet sere H gears sear sah ver sraferat Fs Prdt wrafere at sere feu ae wa oe caret & afte wnte afrat (areafae oat A afagff & vfe & afaften) ar Art erct aearey & arat wr ater axed are cara F gt tar TT |
4. wet we we dfeereré ase % germ & ge are HY see PRs at F wars F amen ax oH art
. dearer St SA are are ar Rater wey F var W, Tet eras 2 FF HE Ah ara a dared Ue F yah yar tafe a ae any are wr Pater wert a oftaritre set HOH, earhs, wares & fore soars ws fA Tet Het fis sear oftora ca aaa Ht Pafee Pare * aH erm
5. are are, Hae ca rey A Pest cart searaa HY gar ae we ore FH ve card dearest A seH ® far
6. oad derrret & etter ware dearer ] arcor ge ara St oe oe sated eet cafe & Patfte fer os
Bray Tar, wa ae Pe sere area arg sre eer vate sre ae Bt | .
7. wet areat Ft ara Ft et ae ofa eet fre ca wae & aq aqeaat F wert A fAaaa frat war Z, wet Ta ayeaat ede ga Va H erat S afar zat ETT
. TATE - 8
—eTrertt atte arg Pong
1. wa dfaarerd weg % fed sera arer aeacerste arerara F argqarat & wares 8 saga arat we Hae set
Tree FHT MTAT ATTAT | .
2. racers ararara F cereal S earerat F Gar afararé asq % sem are ws aftarard asa F qq arat at Teateatere Use H He MATAT OT MAT R Teg ca THe warhte ae Tae 50 were oH aera aba aH ae far AT
wa |
3. afe srernerdt sere wardt waters er ears wa Raat wears & ae ea ve arava cee F aa ser AAT.
-— arent Brat erarst ar ata secre fea & spear aie dar arg ata areerrg afaeard asy F ae & freer Heras |
warerrHett UH Paret z |
4, fardt oftagea cera, ott fad afereré grea ar Prardt %, er sterchite ararare & are aerar qe & oftaga &
fre wae eat H var, sqcerr serar fiery oe fee art (forest Herct H afaga & fay sae Hea wey TENT.
anfirr %) & sae arat, ay writs & a stacasdts ararare H UA werarat aren arqarat } sara & VA arqarat .
HAA WHAT H VS searcaséty Saves S wey arat ST F ara are she Sa Te HT: eras 1 TIT 2% SrsUt mereftey ae MTT ATCA, We aH PH RAAT Here Far afaarard Tey & ftez gt vat a Pee we eT
5. ee aqeee & yates, starette arerara 4 wera waar arqarat & warea & vere wy a aafee Paat av os
BaTH BY VS Werarat sear argqaray % reresar F VaRe Ms AAT TT AAS a VS Hrcrare HT wera & fae gerravTs
& athe apes 11 oder VS sare eater FH ory wef eth
6. terre 1 caer Pat ge Barfland, fae qe vere aoe At arcane were a Ae ft arg ett |
TTA - 9
wear sere
4 ret | |
(*) owe dftereré ceq ar arg ser gat afterard ose fad gern} yaa, Pas aay wht a
WANT: AAT ATATAT: ATT SAT SF; sear (@) we dt eats, oe itera uve & At sere ste gat aera coe & Pet verre, Peer
, array Sot % wera: aera aerate: ATT Aa & . . .

8 ° THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
atc atat & & fret oft area F arat verat & Ste are afters geen fade aaat F tet od cet ae wag are EH Se erat Are g, ot exes Sere ts cat ort oY Rar HE at are at oe rat vet ay A
feafe & sa serat FF cw sera st ore gor ater, fq sa oat % aren ea wae wre eat gar, A a oH Ba Tae rat & orrftre fae or aed & shke Sa TT TASTE HC AAT HT THT F |
2. wet om aftererd ove ga cee & fet vert F arat H oe arat wr afeaferr wear ate TaqATT HK
array & fre oe at aftarerd cer & first sera ee Sa Gat tee F He STAT TAT F ate Tat afeafere fae 1
ara te are ¥ wr weather ase sere St va feat F wre ye ea Ve arat verat & Ate arg aE aed Ga aE
F ardt st ext serdt & dhe oerg Ee ert, we ae Fae Tee ae ort Ie Sat arte ae A oy aT agi
. SATAN UIT) Se HTT Taare BY fer Her A ee Hee Hey Tost A Ma ET a eas F cer eh ate af raves gr, at dfeerard avat & ware orftraré wa gat] are vara HTH
a | agra - 10
.
1. wa dftarerd cee A rare fart weet arc gat afaarerdt cee & feet frareh ar ser fee we arate sa .
Fat Usa A HT Bt |
2.. warft, Be araiet ax sa aftarerd coe F ft ste Ga Tee ergy F aqane Be era aT aay Aree |
RTT aT BCA aT ret TH Pare & Tey aes araiett ar heer eat Gat afar cer ar TH Pare &
ACS VHT ANTAT WT are HT arate Ft ewer TA 7.5 shee & afihs wet sem sa Acrars atthe sar arat
A te F perh were HY erie Tet BOTT Pres F araier arer fire Ty EI .
B. ee agedee er regen arte” re er after eet area ee fret T ore arr TE att seer Frhieer aftteret & are & areeara are F arrefterd cet & ar a seo er ere at a, she fre oe se UT} at tener a cree terre ary Bt dere Bo aT oe aT AT, ek rere et ave weet Uw Ret
4. ors 1 ate 2 & order sa feat F ary vet ait, ae arate or fara eat oF ce afeereré THT
wr fraret ert wren gat aftareré cer H agit fees cH eardt tearey & AreqH J archarc wer &, ferent :
arate sar Hcy are wert fraret & aerar se Fat ree F fore fet Adee cars B eae Saheew Fart verT |
weer & atte fare creat & ater H aratett Ht aera Ht ort & wat ay ee ere] eat dears eer Pitee ery
& wardd wee awe & 1 Oeht Peake FH, weeee 7 a aged 14, ser ot aren Bt, % sete ary gr ae
5. wet ere wert, of om aftarerd cer Ft fart &, gat dftarerd cog & ara were ora wre wet &, at ~
GAT Cree wet are aren Pe ne artist x, Pet aft vere ar ne ang errr, ore ar A AA Grater se GAT THT
3 fret Frere ant seer fare ore Bt, steve wre om fh Fore weaker & are H erratert At cere Ft oret HH, TE Te TAT uO
aren # fora fase ere deares ar feet ae ears & edt wT & ae BF sie a Ht Het & ahdafte ara 1c HT
FATT TCT, ATR sear Pe me arater eee aah arg we Far wife we a se gat ces F sa AT Ty |
MNT rat ara WT eT .
ayra - 11 a
400° ue dferard cer FH vere ay are war gat dfterard ase } Pet Rad & oer fee ans
ARC Tey FHT NTA AT HAT FI a, - SO
2. ware, we ware & saree ae se afters Tee F ot ate se Te] Mga & agare We HAT HT THAT g . -
| Foret cree a ag sage ater 8, Reg afk ear ar ferent cat get ifterere cree ar Perit & a ee ware spares ae, sare Ft are cH 10 eftere & whe ae ah . |
3 | 7 | 7
j

Cant Ileus 3(ii)] AA BT UIT ; FATT | 9
. 3. terare 2 % srdat & are gu ot, cH afteraré ase F saga ere we sa eT F Hr a Ge TN alt Tet f& xa Freferfere & are ova far var a atk feeartt wr @ frafated are aaa caries F car war a:
7) aar afrareré cee Ht acne, sear are afte sa-carT arar rE earefter wifirHcT; serar
@) (i) aver} area 4, aredta fear Fa; aredta frate sare fm, creda avandia Sm; sitz
. (ii) fteter are F, deer Fe ates tera; sever .
7) we wey sears Pref got se cee A aeare are Pt earhter are & aa fra ve wat H arara-vearat afta aftareréd creat & were orfirerftat & ete aaa oe went ge Br
4. we age F rar - sq “oa” oree & atts 3 - vate ware Hor sae erat B wre ara, we FT ae are whee et arerar vet she arg See eeT-araT ara F afters wr are aftrare oe Vt waar vet at oar fare
Sr a acard sftqaat a, wre ara ate seat sear aera & wre are Prat tet sftafeat, serve wear a.
wat & aatire Sifters ate qeeart onfire af 1 oftaa weraft & re adee dae wart Fr va aqeae ] sah fer sare ret SAT TTT |
5. horas 1 ote 2 & soda oe Rae F ory ae ai, ae oor TT Reet ear, eared ae eT Rare
BY gr eat aiftererh coe, Pret ear seas gar Ft, Tae ere fet earl dearest} arene B ardare FCAT
Bt ara se Fat wave H, Tae fea Part foes cars & cada Aahw Mare Pearea sar aT site re ae-are &
art & sare arar fear war et ag ea ere cart dears aerer fAfdes ears B vardt wT a ares a Ta ae
H, wyrae 7 weray aepeere 14 orate, Ser st rae By, ATT BT
6. sare firdt dftererd cer F say ger ara are, ate sare Har Her arat va wer aT rare BF | .
way, et sare sar HCY are safes wT, ATS aE Pret afrerare use ar Pare st srrar-agt Pret arene wer
= H wa earl dearey sear fafeea care & att ca ate F ae werer fire oe ware vee Par WaT aT, Fa THT BT
sare Fe ware & eared dearer saan fAfoes cars are seat fear war B, al ea VHS HT SAT Sa TET FIT BST
rat ore Pere ag eardt sears sera fafeeag ears fara ZI ,
7. wet, wer Hey are atte fRerartt cart sear sa eta H Ste cer Pet wer oafte a he fate ade Bry ,
HT HAT Ht TE vaTH HY THA, Ta ATTA HY cara F cad Eu fers faa we cH Hear Ft TER, sacar a arg —
ort &, Freres erater HY, cer weare Oh ater et ary At feahe a, ger Her are she ferent cant % ate, aeatt et we .
See, wat ee aR H ore aif we afer Ca ee Ht aT aT AS a , carat anftrer wT ee
RU h oer sae H cart F ad EC vets aaarare Ter H Hat H HAT HT AAT TTT |
: . ware - 12
1, wa dfaararé ase Ft say at are ate gat afteraré asa & fret Part st ser Ft we crafecat ar aaettht tarat % fore qen ot sa gat afarare cea F He TAT TT AAT | .
2. - want, xa ware At crafeeat ar aah tarsi & fae qos oe oe afteraré ee F of, frat tage ge
Bt, ge cree H angat H aqare we Tra oT wT, BT aS crakReat ray saith Tara F rq ew or eat
Tara Zar afrarard wes ar frard & at ee Tare STAT aT He TafReay ar Tat Aaa fer qea Ht aa
| afr % 10 sfeere & aftr at err . _ :
3.(m) we ayes F Tarra “Tafeeat” sex ar aftrars g - Peet arfeers, serene, erat Serf Bie & Pret |
arftcred, rad fares Pret sear Uear sever qrashr varcor & fer wae feet aan 2S gear few .
anftre &, fret ez, teak, eorga arar ateat, soar, qe ET aera after vat Ry array eaeTfaTC

10 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
dq seer fet chefs, aftftes seat afte seer wate oq warmfbere Fq gear shelf, arfirfien sear aoarfte aaa & afte gaan % fare wt & wr at ore Ft we Pet At ware gra (ew) we waar F ouer-agen “aah aarat & fore gen” ve ar afters & eet sear arr afta A ara order afer hE aera, ar eet sera Teeelf ee A Barat A aftr HA ae At ot wee |
araraftrat &, roe rat ee arere eyes 14 war 15H afterfhrer erat Re A we seventh enfire at zi
4, darare 1 ate 2% ora var fale ary wat ait aie Tafel at oath Barat & fae gen ar eer a ert, ay we aftererd ave ar fart gre ge gat aftereré ave F, rad cafeeay a aatet aarat & far
Aen SayT Ker &, Ter Ie fers fat card dearer F areas J arcane Hear & aaa sa FAX UT F agi ye few fret fafoerr care & exe dafien sarc feofta wear & ver fire aftrere serer aeqte & aa F crafeeat ar went Sarat & Fey gow sar fear oer &, Le eardt sears sear Peer ears are warat wr a are FI
RS ered F werfeahe aqeke 7 array angele 14H sade ster th areer wy, aT ;
5. (m) wr ferent cee craeat at re Rava FB A ew aw SET Far AAT STMT, oe aarNAt ea 7
awa, ger ete conftfts goarerr, a eaefte efter sear St Ratt at ah, wet cafeent a :
ae Sarait Be fRre gen ser wc Te athe aT, TR ay At efter ree er are Bt area aE, |
oe dfrarerd ase & tar ere eardt deers aaa art fewer era wt, Pere dae F crafeeat wear .
— whet Serait & fee gen ser wer At revert frag we wy, othe Tet craeeat a7 reihht serait fac .
age ser eer eee area PAA ear eer ee Aha er BY, wr Ret craPReat era eth eat | |
fore qe Te ee T ST yar ArT wT Prat ag cardh sere sear fry erry flere #1 7
(a) rat ort () & see Trafeeat sera aarttht Sarat % Fey ew Pret UH atherere creer H SET AT Es .
grat ate crafecat, aferare arerer aeate & var aerar varmfirere & aati BF srerar oenfhht darat & far en Piet un afterard avr H Prearfte Ft we Sarat S afer & ats crafeeat sere wehht serait as
Ferg gem ser afeereret cree H Ser FHT ATAT TET | . |
6. wet, warnat war feat earth & Fre sarar sa atat site frat wer eres hw fleet ary ware aT eae |
Ber reo crafeeat ar cathy oaratt & Fre gees Herb, wearer, werhrrPeee ar TAT Hehehe H, fore fry ae . |
wer FY oar &, HT eat H cat eu va aft & ahs Bt art & irr se Re ae MH oqafeahs F gerwat Ta |
ferent eardt are went af we ath, wet xe pede & ore Hae afte aftr cat ae ay AT 1 VS ara F, - |
sraraft aor anftrer sr ee mee aeT geet a eae cad By, weds ieraré cree H ait F aqare _
woe SH | |
aye - 13 . . |
1. yeas 6 trerar-2 HF ofPafire she gat eRararet cree F fla sere weTAe H steer F eH aaa urea & fret Praret are wre afrerat az va gat ase FHC TAT OT ATT | a
2.0 Ret rer aft & stare & tt are aha Ty, a TH share TT & fet sere H gat afeerart Te
& feee fae eardt teaver Ht arctan cafes ar ww fear yo aera fet fafdee carr & cafe det se aah |
stereo & wre A aa ara oe, ot aah ww stares cee & AR Rait st gat after cee Fade i
| |

, Cart Il—aue 311) } WA Al UIT : AAI {1
Safire ara B vata sree 3, Pree Pet 0a eat sears (wee sera qt sera H ara) aera fee ear
% xacr F aA are arava At ra Z, Te Gat ass F aH TATA AT THAT
3. saceresty urarare earfera werarat aerar arqarat aac e afrara aeray VS waar wear avqarA
aarad & cafe we safer & are eae sa ahtararet ase F weeds ay ret sacorpeat wH rare 21
4, Fart aroeft & gotta cate & trad & starcor & ars rast afer ahrarard ase F fora are aafer Bt Teer
TAT are SYS Ae sre &, Te Ta Tes FHT TAT HT HAT FI
5. trav 4 & ofeerfera rach afetter arg aeett, ott we afteraré cer Ft Parc %, sat rac % stereo
& ore ararat oe Sa Teg F HT TAT TT
6. dorare 1, 2, 3, 4 var 5 # sfeafea sate a fre Peet ft arate & steer a we afrarat ox Baa et aftarard ase Fane am aa, Brean sercornat wa Pare z 1 , .
ayeae - 14 |
1. wa afaererdt asa & Peet frardt are aaraarfaes serait} fAvqres array edt ware F eg aa aay wade ardmarit & ore art oe ee oat cee H ae aTaT oT wT, Tey Aafafea afefeeaat H after, oe tet ara ae gat afarerd cey F ft we TAT IT aT :
(m) af S¥ aot aramardt & Roqes Bo ttaard, gat aera ced i ws Aftaa ea Rafts wT a srrer % at Sa Nae FT Hae Sat ara we Ta Gat ae F Ft He aT oT aa, Tae fAfeas ETF
| HT Ie EC ay TAT :
(em) ae gat efiterarét cree Ht gets aR A aeaTRY a afta daira cnt a ret area TET BF
- art Pret arcg met At raft ager Prarae 183 fer auar sad afire fea gi, a se mAs F, are rarer seat At arr oe Sat at Tee FT TET TT aT, HY Ve Zar Tee F Say are Peqriee art-werat .
& ora Be eT! ‘ | |
2. “arerarfts tare” va & eat deniers, arigfers, serers, Afers sear searea weet armors aa
Pafeeret, wétett, werd, areq. faa, rea afters, de Parent car Serarat ext ard amare erie f
| | aqeae - 15
1. aq 16, 18, 19, 20 ate 21 % srdat % afta cae ge, wa aftarard cer & feet frrareh aver Pret
«fatto aide Bore Ae, orgie ate eat ware ar rR oe Beret eh ee He a, oe TH
Prater ar Porras Gat after éh cree H at Par va 1 AS der Rett Pear mar &, a a feels wat a |
We SATS, ST VT FA FAL UST F HC AT THAT FI .
2. dorars 1 saat & araye, we dftererdt asa & Pat Prardt ara gat afaararé cee F fq ae Pet
Retort & ater & gre orfbatites oe Sere weitere cree a are aera or ah, WA |
| (ws) wrawvat, aiafite fata vd & aera arerar oreo gE At ares AT A Ae raf oreray aah B eet ase
¥ <g car & Gh a ara 183 Rat 8 afew aa FZ; a (ey arf fire Qa Fret Patore rer aerat seh ate Baer Bre var &, St se get ePararet ose a Raret |

120 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
(1) 0 orferfire te fat earth dears aerar fAfSae ears aver age vet fear oar 2, ot fats ar oe zat aftareré wee FB
3. we gear & edad odet & areage, cH afterarét cee & feet see are aercenpta arerara # warfert fret tre srerar argara ot far ae Prater & ear F ore orf oe, set cree St He TAT aT AT |
wpa - 16
Preeti dr.
Fareeret Ft ote ate eet rege Ft ser serahtrat oe ot Uw aeerere com & fet Pare ere fret wert,
WY zat feared cvs A Paret &, % frees dea F aaen Ft Bfdae S wre Ft ae a, oe va Tat ToT F a
ATTA ST BHAT |
. aaa - 17
warert atc fran
1. ape 14 she 15 & ooaet & erage oft, ow afteraré cee & feet Pere ever werenrz, Sa fe HE
firtex, qafier, URaY ar geese warere array Pareht aafterare area feet Porst wa F get efdererdt aw F
fe re ge ware eat Aare Homer F ore ary Te Te TAT THT FHC AATAT WT TAT | .
2. wet Predt serare orrar fret feast ere aed ga ware Ft eftae A Par we safe ertewardl & dae F
We are eae Mera aT feast Br ove vet Bret, afte fat wer oak Br ore ardt # ay, Bet ara oe awa 7,
14 ate 15 & sodet & erage, ge afteraré cee A ae ara or aa, Pret Hereare sear frerst ard-nare fr are ef |
3 ferare 1 atte 2 seater fart errant arrar Peet feast are, gat dftererdt ase F fry ay aay art-
warat & after are az any ae eit ahs gee aftararet coq F PHA as erdHarse wH aT arat ararare at ar _
_aarfifes so vanit ar sam eorita orftrerftat ft ardafta Pftrat ere aafiie at 1 ta area F va ore oe ay |
oat afarere cer H ae ater Rrever ag Hera aT fast Pare z |
agar - 18 | _
1, agar 19% tears 2% srdet & gemefta, wa aftarare cer % fret Praret at seat fae Pater se were wey F ear Kt ve Tera ate eat ware H wer oefhafte athe Heth arfhen ghee oz athe VS are wr aay A aE |
Foret anftes afer vx tere set arse F HC aT AAT | an
2. “anita afte" oree & arerd & eet areray rt eu] aera water she Gor wher H awa H aarahtat Her oo fore fardt aremat aga sitar % cher fet fafAfoee aerar favaa safe & eho fafeae aaa oc orafrn eT a -
weradt ary arg Frere ate | .
. aqear - 19 | |
acardt Far
1.(%) firdt dftereré use arar seh fret ooertite so warn array feet corte often ara ga UT sar wae Pret corti Soran sear Prt earfta arftracor caer FT Fh 7e Farait & fore Pat as st arer
Ft 7§ tert & Rew Far, Tore atte area eet ware & oforfirs oe Here Ta TST F ae aT
(a) warft, Ba Fea, wage ate oer at ware arfoahtes ax Har Gat areraeret cor H avi we athe, afe
Rare se Tree FH are at ste Ten aS se Tse wr Pare st, a: “
(i) — - se ase ar oH aes By; aeaT |
(i) arr dart var eA aT 9 Ge OT HT are AE wT eT .
a
| \
| | ane ft
|’

* Carr larg 3(ii)] AG Hl UAT ; AAI 13
2.(m) feet dfrereré asa aerar vam Peet corte savant array sem feet carte sofercor & fare Ft ag
Varat t dae T Peat as at sa cee Haar ses fart So-warT aera fret weber arer sae are Bere frfrat % & ar ga ® aren wear A we ters oe Hae Set eT F He aT
(a) warft, tet Yara oz gar afdererd cee 4 az ast air, ae oe a va gat ae aT us fart wer uate a .
3. ayer 15, 16, 17 shx 18 & soar Pret aftararé cee aera sae feet carts sara array fret earths srftrrcer aver fire or ee Peet wrcrarc & false F vere Ft we Aarst H ade F wre Aaa, worgfeat az eet ware area orfoefirs sar tert ox ary BT |
4. we aqeae vir, “acer” FH ete cee acare aay Sat FS Pet At dered oe wT te , wrfiracer erie & i .
ayaa - 20
1. - are Tree, wearen & aerar ethernet of cee F gat feared fees fact favaftenca, verftaray wear
ST UST Bre areTarare Pet ceara F farerer aera ether-ars sera Spay HCA Are Sa TET ar Mey Hear F ke a sa at a ger of sa gat aftermrd oe ow Part & aero at Ba VA fees ae he at & fa we
Urfosfirs oe tary sa zat cee FH He a Ye wea St | ag Ge va arte F hae Saat s aafos A aah fac
# aq arm, fre aréte @ ag afte va wearer ase at rere: ether Ha 21 .
2. wa wee vata, Pret eae wr fret dfeeraré ase er ow Pardt are arom, afe ag sa fare ant & fret ag gat after cee wr eter aay F aeaT Sas Toner Wad adie ad F sa cee ar us art
TE et | |
3. xe torres & wararg eee ‘arevar sree deara’ & arerd t wy tears of ca dae F cafe aftararét ase Ft a ACHE BIT ALTA ITT ZI
94 |
‘ frardt
1. fart fred ar, or gat afaarerd cee ar eter wer F Gow ves Peet ww aftararé csr ar fart &
aeay ar atte at are art fore aerar after & watraret va gee afdarerdt cer Ft safeea %, at aqarat, aeot |
ate arraftrat atte sar srcor There, farerr srerenr oftreror 3 wetter ser crea are areal Barer Peed arava te.
afafeer sr warafiat oc sa gat wee F we & ge wre arf wt ag feet fraters @ ree Heer 2 fre ag Gat afearard ase F weer & ahs tar raters sa & wea & vert BTS Taher F |
2. Prat & ofesrfite & ark & tears 1-H aenia srereer Ye 3000 waht stare whe at & acrax ae a aftrs wat erfh
3. ae aqeag Fare Hae Vet sath % fore ary att ot PH ge Pe ay farerer evar afer BT TTT HoT
Faq sre aerar arercorrar artferr et veg, Pret oft feat , Peet at oafe at xa aque F are Ta Gay .
aftararé cert se A fire steer wftrerr watered as cae: War A arte & oeanrx ae ast & af F
Ferg are ey ete oe
ATRAT -22 oo .
ay aT
1. wa dfaarere case 3 Pret frat A ara At tet ae, weremdt a sage are at, fr oe xe aftrary &
ater oqeaeat & fare vet Pra war &, ete Se eT HF ae ehh
2. tome 1 Horde, agree 6 & tes 2 H aer-afonfta aera aeaa Bere are & Pew arr ee ATT eT . |
ait, whe Tet are ar orerwat uw savers cer ar Part ar ara Gar dfareré cer FH at fore fat ert
«(he é Cn} lu-k

4 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEc. 3(ii)}
aearay ¥ arene & Hrerare Heat & svar sa gar afaarard asa F agi fora feet fear ena a cade Aafia wart Freaker Hear x car Rar aftrnre seat eerie rae ater H Cet arr ager Ft ordt Fae ta emt sears aay afore cart & varat ey % ares & 1 Va ara F aqeae 7 waar aed 14 F ora, Het ott fale FF,
TT BT I
3. terme 1 ste 2 oraet & ere ye fh, Pret shearer cree & Prareh Ht are Ht ae fer ox ee aR
aaadt arpeeret Ff Pare vet fara war & ote of ae afarnet cer F seat HES, TTT FAT TTF HT TAT STITT |
| aT - 23
RC WT HT TITTY
4, avait HF frat tt ahrererd ave F vga erga safe aftareré cer F ara} Hepes a aaa HAT
aret wat frara se feats %, wa ga wae H, ga] facades are sree far var Sf i He are Mtat sfaararét asat ar a area & at xe onqerre Preafetae terms & gare Saxe HE F ee vera Ht TTT |
2. aeae: .
#) wet sree ar are Prardt det are wre axar @, fra oe ga Hee F Sasa F agare Atetar F war
SITAT WT THAT Be, Sr Ara F area, Sa Praret Ff are ae feta Ft war few ae He & acrax FF
orf Ft wetet A qa wera wt | .
wart, tet weet Fr afer, achdt fare wrt & oF gor-aaftre, ac ga art & aftr agit :
SA, Hr Ret sre Re reer wy, Pre ve tear F we oa wr awa Fs
@) wet woe Pgh soaet & aqercoy F area & fat ard aro wre Ft we aa rea F Be YZ
wre & at, acer Pac aft, ea Pare Ft art are array ot ox we FT ef At aa HAA BT TH
Qe-aT ara HY CATT FLAT | .
3. freer & :
—— Qe) wet efter ar Ste Preret RA are ore Hear &, fre oe ve Hee H aaa & aqare area F aK
warar wT aHat &, wer Aree area FT star fat re we eerae aie Ht sa Part FH ara ae ae .
wetdt ee FH rate Br .
warty, tet acheter sa arr a afers vel art fore ge Pea art & ot Garfre Pear wer Bt, HY Ta .
MrT ae areren & re ae area HF He Aaya Aa ¥ Mar At Ara Bl |
(=) ret were & faregt coaet separen F tera & feet Rare? aver wre Ft we area oe tet H TF
We wre & at, ofteter fire oft, OR Part A anh ore gear yo oe a A TY. OTT _
BRT TT Ye WTA are HY ears F TAT . .
. aqeas - 24 . .
AA -ATARIT .
1. we dftarerd avr & afpat oe gat dftarardt ase F ar He we erar oedeelt Teh HE ate ATT
wet A ares wt Sa werera & ake aedeeft sternal & fire aera afte arco gt, wr va gat ave & aay wz fatten: Para dee FH sgt aheeafrat H ary art St array ary A or aah Bt eqTeae 1-H sada H He ET
at ag sade oa eaftrat oe ft ary eter WY OH aerar eat afaarard cer Pare ae S|
2. Tem afearerd cree & felt vers & gat dftarard aves F fee cart dears ax Ba ger Tse F tar HE
moar any ae fear wren wt se gat cee & gaat ve aad arma A HST Aq TTY A ae BTA A
HTATHT HT ATT Bl AE Saw wa shared asa s fer gar afearare cow & Park Iat wt sah fate eferre area arRarhte farrarkeat % sree Te Here water & fore Fee were HF Cat ochre Ye, Tet aerar Hethrat a
Fr aig B® fry mreverd aa ware, a eg ay Paritat tar 8 1 ee sade ar ag ant at ST oT PF
wae faet dfterard cer st gat aftarad ase A fet wert & gateafer ces F fee Pet end geass J
oo, a | |
L
i

"Cert Ilwaug 3(ii)] AA FT UAT : ATT 15
Bare ae He A tet ee aay S CHAT J MT PH ae Ht sa az S ca witaaa a aflrs vet eT oaatfeafar aftararé ase FF tet dt wert & arat ox org ord 2, 7 et ae awa 7 % tors 3 & arse & aftga Fz
3. DS ares Hr areer wet aqeae 9% hoarse 1, wqede 11 FB Hos 7 a agra 12 % tcaTs 6 F
sree any are ¥, wa dftererd asy & Peet germ are gar afterard ceq & feet Prardt st war fet 7a erry,
, card wear see rare, BY ger R Hees oat aT Paton ae Bo watward salt af BH aqare wet ahs gC
aay Saar araray were feefers cree a fart fare ar Pear war st |
4. wen aifterert cer vert oe, fre pot vere ar arent we a aye aT sifts wa a gar afearars .
cree we ar afin Prerfirat & earhrer F et ar sae are Praha Ft ort a, veatferfea css FH ars Var we ; wet aerator ar aeeaelt wT ehh seer ae A reat a Ta Heres B ate aera atrarait & few array ars areget &, wr weratfeaiee crea h wer cat ware H Sera ae ary Ht are F ar ary Ht THT ZI
5. wa HVA Bray, ca were F aftafera at a ay AT |
TTA - 25
. arceaftey were FAfY |
4. wet ere exis ag aaa & fh cH aaa AAT afaararh cet F artaréat } are Va Ve Ee THT BT
MAT rat & eeAT AaTaT aT A va afrana & sedate aqeq ae z at ag Sa Teal F eae Beet arg arafire sarat oe sare fier fear aoa area se afteraré ase % aera wifererdt a weqa wx aaa z freer fr ag Pare & arerar aft sear aera ayer 24% tears 1% sete aren Beat ag ara arraT sa aaaraTs THT
3% were orftraret Hr weqa ae are & freer fH ag abs A ze are Ve areas A ee afar A atte F
fra ast & frat sara sveqa ax Pear aay erie rae ofeoree: sa oe Var RTA STAT TT ZO ee TAT
oraet FH apes wet z | .
- 2. afe aera orftreré a arafer shire at atte aft ag cad fat datos ge ox agar Hanes st at ag Ua woera & oere Ft gfe Fw xa ahrare ] ayer aa @, gat afarere oes} aera wears & are oreenfew
AeA Bre Se ATA B ST HA HT WATT HG | ea Ware Pee ae feet At arate a aratieae fear are MF
areas creat & eaaeht argat Ferg ft aaa sat aT BT
3. afte ga ahrany $f earear eet F gear ea ary wer AF afareat sear sare vers at ay afaararé Tet
% were wrftrere seg arcectts sents F ga Her Hr vara HET | A Ta Aaa F fh alee woes Bt ae Her |] fay
Teent Pare-Paret we ane F Revht ee aRraae F oraear wet Ht TE BT
4. flee dorarat ® aftrore & sre aaetar wet vara dered asat FB were orferare UH gat F
area att vr-sragre we aad E11 we aaata Her A gfe a fread ar aifes arere-vara Her BAe Tete a at dar arara-wara De arayy h afer fear or aaa & rast ararare sak & aera arftrarheat & wafer ere gh
; aT - 26
AAT HT HATA-TATT .
1. dftararé ceat & aera woftrardt tet gaa (eerraut array cearaat 4 afisrnfire sfaat afee) ar
HATA-TeaTA HUY GY PH ge HT FH Sade BT aT Her & fae arquifta we & ara Bt aerar aftarars Tsai ay .
was Tons serait ar carte sft Ah ate SF are ae ae ware a ae ares sa wet a aah .
aah erat vere aerar araferaa & feu aravas- at, wet oe fe os afte wort Sree Fa RTF
serge et 1 aa ar arere-werT TTS 1 ate 2 are vitae eg sI
2. Serre 1% starter Peet oft afaererd coe gree wre Ht me ae At Gra ga eT } sates arg &
ama wre gaa & aera Ht ye weet arett ak wa ea oa aafeat ava oftarheat (Rat aravat atx serrata Parr efter 8) at ware Pear area ot terarg-1 HF defer eet ade Tet ar Autor ar sarkt agett .

16 THE GAZETTE OF INDIA : EXTRAORDINARY (PART II—SEC. 3(ii)]
WW, BAS vada seer alysis F dae F seer oetat ar ftatcr wer a sede Ft aH a tae et i ta ahs ar arfirer& qwar ar seater are TA gt sates & fae Hey | A ea Gaa HF ardahts arrarera Ft erfarieat sear varie faolat Home wc ae | Ghadh gear F ate ec At, wn aaarerd ceq are wre Ft we Gr FH TAX
warerat % fer water farar or ower g wa Cet Gra Ht AAT Tat H orga F sterfa Ne sea vatwat & far war farar rar er atte arg fferat cree ar ere srftraret te sary at aferper TAT eT | |
3. Pret fh feat F dcrars 1 she 2% cadet ar oe feet afaarerdt oeq ox frafafea after erm ag .
arr: |
*) se rae zat arava cer] arpa ate garafe we a ee aC warefHe sare HAT |
me) et err cee aera zearaat A warftre stat tar oF sa sera gat aftareré aver & arqit sentea serar verret Ft ararea feafe H wrer ae & ; .
a) 0 tet er vere or Pree HE oT, area, shettfits, aTftfoee sere errrerfirs, Tih arar sarah wiar srerar aaa wae Bret at, ferret ce Hear ardwften AH (afew aréz) F
Bic -<i8
4. we ae] oar F apy feet sharers ase are Pet orraret Bt wre He] fre ages fer sar
& wt eae afkerers cose aan Ft rk wrverét ar ore Her & fare sett aaa War wey are Sorat a Tear
OT, A Ta Hey cee HY TA cay Hae watt & fae ee Gear HF HE stave 7 efter ane F
arafttee arfter terars 3 4 eters ® afte 2 faq fact oft feaft F tet dherat eo ag of at atm fF
afarer dt cree tree eefenr qaay Teak HCAS war Hee ¥ fe Tet awa F vere HE sao Ae aE
5. fired sft feafe % torre 3% sedate et Fee cater ger A argh wer a war wer fer fact area cree wt oqaft Bt fare et aera sere PR aa fret Se, wer fetter aeara, fir watelt ar Pret |
© Bare ererarr & wpreier andre ar echt te ore & ar ae Pet oats earfrer Pe B cafes &
_ aye - 27 |
. wet t aaett aerrer
4. afer cer corer erat Faget cw gat St agrneT HT Merah oi & aan fds we |
| argMeRE srg Fh PAA eee aEAHS are TT HT THT F | :
2. Te awe H me TER eee “Cre Tray” aT aed wer H steer oy ara He H ade F Ba OAM ate Te , aftr & dafite carr, afew atte aaeht Ft arre aerar care & ade FF 1 afaararé asa, ava gah Tandon :
TTA sear earthy orftrenrfeat Ft are S are ae Het aha KeT TET g | -
3, owe fire aferertt cree ar croren erat Sa after cee at & stent vache ghar & ate ag feet -
aah are ta grat & ate sa aftereré ane sa aes & arpa % sata eadt aeelt a Oe dl aaa ae oa
Frareardt crores are SY se cee aes orftrers F eycrer x Gat Shterere ass H wae weftrarheat aver wat a
% watorand efhere fray orga site Se Tee ars BT Ta Fae afaarHe TT are aay cay | Het Tada atx aa, & fry water cae erat % sereet & agqare age Pear orem, arat FH aes arar Sa gat afaarare THT
BT UAT aTaT aT
. 4. oa fret aftereré cer ar cred erat ag arar 2 free aa F ag aftarard oeq, aar are & seria, watt vast at aftited wet h fae deearn F sore Sea 3 Wa Ba TET TA HT oe afaarars Te} eA
arftrare % aqtrer ox gat aftarerd use & aera wiftard aro dearer] Sate Her] vatorand ehhere He rar aN | Fre Her ater ws sa crores ars H Hae FT TIT HPA | Saat A aqare Herr H Sere KOT aay :
Fe crores ard Be Tat aftarard use] awe Ts 4, set oH PH wa VS Sarat ar ater Pear oer &, TET eTaT _
wanifeaterr atarerkt cree H weadtte vet & rear Ter orhen are tax B Here gearht ageht cows a afters Bi -
| | | F

° [ant l-wre 3(i) ] WRG Hl UAT ; SATU 17
5. ee ede & orae fat afaerardt use} ages oe dae oot are at we Te a araTe, TTF a mrp & aed saat & at ether Sars Fase Bt We eT I
6. terars 3 ake 4 & saaert era ec At toms 3 ava 4 & yard Pet afaerarét ose are eta
Pear war cores erat ga afeerarh cee % feet aera dtr & seria vet gh sear eet we H Va ea eaET
wreoy we fares cree A aT atentea et corer aa water SE crafter aa A areal | gah arava, aerave 3 arrar 4% yatorard fart afaeraré ose ane Starx fre ay cares aa a va aarard oT tat afrererdt usa argat % stefat sa wares ara vatem are yrafterar ae Vf |
7, fart dfteraré use cnreg ara & aftr, Sear aaa uty & cater F ardargt at Fae Gat afFerarét urea } erereat arar verafrs Prarat 3 are gt ara aren | ea apes F Yar ee vel & rear ae eax afrereré cee & Prt eararera aera vorrafae fara aver Uet artarg & few Pee ahirare a fra Hear ;
TATA FI TATA BEAT BT |
8. wel, travs 3 aewrar 4 & age feet afteraré ces are aque fae oat & qeerq feet wae sie cat ; aaa fe gat aflarerd csr FX ara Tes are Bt age Pear Vt she weaieafas areraré useq Hy Ste fear zt, ures erat agi Prafafers & deter Haare et aT |:
) «feos 3 & aati age F ares 8, samtfeafee deere use ar ME TEs cra WT Be afaararé cer 3 arqat & aaa vada & sie Ve afte are aa 8H ea wae se aaah TT
argat & senta geht aaett tee ae MHA; aera a
, @) dos 4 ata age & area #, sereafes eared ose owes wa ek Sa Hag aPrerare cey rey erga & age east aah ahora Her} sees a AVTH TTT HAT Ft z
. wanatee after user a vere oftrard ea wer at gat aftararh casas aera wifraré
L oY wenrer aftrahrer Horr atx ax dfreraré wee eer ot wenafee afterart ase arr :
9. we ayeae % Pref oh order or ard stat Fe fet ot afaererd coe ox Prafefad % fore aera ary .
%) va dfearerd ase seer gat dared ase & arqat ste vara war & fer verafrs sore wer;
@) a sare Herr TH ars AA (ade afer) & fare st,
7) werrar wart wear ate Fat afaarad Usa +t eas Heat Haar serafrs yar H sete Voter aget waar dare, ser ft aren at, Be aet aahea Sarat st 7 far Sy;
¥) a araet F Aerra Wart HEAT Har Sa Tee & fora varafrs ater Gat afaarardt aer are say far ot are ara a eae wa aT Ha aT
aya - 28
arat ar afer
1. re ara FA rg raze Ht at gar HE Car aries (Peet oaks a fra) at ow afrarard cee ar fare 2
war at gat aftarard User Fo os wre Wea Sea RH at oat Br aes eh ST Pet afaareret THT
frarfeat at ast far ara & afe te fraret agar ore Pare &, Stars Acros 2 F afearfha z ate VA arat a wre wer 3 fre ga HTK AT HT a BY YT HA BT |
2. fait afferent ase ar arg frardt aft fardt fave ad & fee agar ore oats ahr afe dar Part frafefed a arg cH ah. | . 7 _
am) acardt aa; waar
@) dat afrarard aval F a Pet ww F Paria arg weet, ae .
Lye od |e | | |

18 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
i} gee dot H yer At xa aware oars 5 F fee aera we ees He 7 oes
& att svar Rafha wo 4 we aoe ws F afte aro we eels CET F arta fro ara &, FIAT .
ii) weadt FX dae Hr aaT ate sear wer ar ae S He 60 afters ax Pret wa afterard ava F
UR aera eee afin saitrat ar vert wT ST TAT areTT ET A aera Pet ot afrereret area F afte seed F req softer ar wer & we 50 wfaea ar ae ate wear sax yor arar fee art carftrer at, ot feet wa aftarerd ase % us sear cad afte aftrat *
- Verraar serar atreraar carhtes H el, away mT) ome arefterdt aera aaferat ar avon, fora ae & we 50 sftera aera cae afta feat fat wm aftarerct cer & cw ear cae afere oaftat & earhtrer F at arcane oft aftercare avr
% seq eaferat are Pare seett F, rer wae ate er ee a ae 50 sftee sear aad aT eT ; array feet caries et or Pet wa ahrarard cere we sear wae & afte orfteat & werereray waar qoeraar caries F BY; aeraT _
4) art ter oath deart sear wer ae ye we ae free gaa erteers stat H & Peet at ow aftereré ase F ware wre 21
aed fs soften saftrat a were avatar aferare wre aeT ETT AS Heres aes Fy Pet oa Ft 50 vitor
& afta ane ara te eaferat ar star Ft ordt & aaa WE TS WTA KT A HVAT ayer wT a aaa ael F WM IA
waraftat & we % shit HB feet oH aftererdt cer fare et F Ht ce Here F eres He arora | wat attr Prerre cer xe varrared wet fer wrt area 3 (Teg cast Aeral rar areata aeaky & ercharc & few arereraar wafer wy & Pear war (aed Ae Bz) qos war faite arewarst Bq Pedh Fes earh dearm, or
Sear a a Pet on afderere ose F fae gs, & arcane aaah Sa-2a FB qrara oe AF Te Oy ofa wat Mh)!
3. Soars 1 ate 2% sree ary aah Shr oor ws afsarard Tee ar arg Pare gat es 3 ore AF aE are Ft wa gay F Hee & arat ¥ few az stm, aie oats afer wa a Para asq F arcane Garay A (ag * are frarfeat Bq Fae act sear sracar wer % arcane & Pew arcrarz, wa oH fH a afafafrat afi, dat aerat wfegit dat wfafafirat a at) ake gaz aftararé ceat & ora Ft 1g are va arerare % tae FH wre HY TE St era wrattins gt arc ag fraret da aret at ore Her Aq ea Hae Ft wer at B age gar Z | oe
4, wa aftarerdt tree ar are Rareh at cam are ge ft Hae FH aay AY AA Pear ore VY gar afrararet -
wree ar vere orftrere ae Patter acer & PH ta ook a dears sag aha sera aye war Kas Warerat Ft -
STITT LH HOT AAT BY WTA HEA FH LAH Ga Taal FS HE UH FST
5. ea aya & vatrard “area wre eaten Teast” ar ater 2:
*) area H, are eects wae ra Fafa aeare are wftafs afar (fAafana) afeftar, 1956 Ft are 4 & wee arerar ft wat at;
@) ofterer Hofer vale wa Pere arte Barada area aE aft ects aa, atx ,
7) wre area ete HT Pre ere wrferaret ee eas H vatorat By Area Sy fry TEA Ve | | |
6. Ba ages F atafttaa Pret ot are % ate gu, Pret ot cater ar ea wae ] ary vars ar aftrare Tet BT, af sah artrary ya wart arafead fry ae et frre gam Stes aeray sae saeal F A HE wH sa He HT TTT
aeaT BY fara 1x AE WAT ATT BAT F .
. |; i:
i a l
| Ot

"Cat lle 3(ii)] RG BUT : TATU 19
aye — 29
aerite fret aver va weet Te xe were HF Pret ft are & aeacaste arya & araren frat & atenta awar fare sere & svat & seria crarafire frerr aerar wttqett aftrarheat & aeent & factte Paererhrarct ve Bre ware wet TSA I
aTaz 30 .
TaR BAT |
1. afrareré aval F) went ge were wT ary Bea Pre aaa arate arqat sterta aafere sires a yer Her & ide F cots areal & afte fafa wr Fw get HT afagPra TH
2. ag wer, Ta aa tras 1 F aheafea eae afer Ft ade st ary aT
3. wa Hae & sraet ar rafatea vars er :- .
) area 4: se ay, fire at & are vqe Brat Z, F are aqardf Heese ae A ate arg F wa faz
St aay See are arte HA ava Pht fae at Fore He aT; |
@) Serer Tare aya heer ad A cgelt ate a sa are arte BA area Pet Herta ae F see are eater H, fra Here wee Ba ZI
4, are ae ate Hott oe act heater F Aree creas aftare she Tarte aera & fore area Torey Ft aeATT
ae arenas warmerdt worcee freer fre aRrery 27 rae, 1982 er gearatta Fea war aT, BT AAT BT
orem at ag Prorardt af are wa Fe HT Ted ea Hea ears 3H Trae F MATT FH part B wa |
- wee - 31
ware ug wer afaieea wae aH aT ca we aw PH Pret afterere cee are et aaa aet Be fear ara |
ait F & are oft aftarerd ase ca Hae ] ary ay At ada F Sax aie ae Ft rahe Ht ama % are areeq BA .
ara fat Faeer at A ears a ae a we ag aay vee Torafae aera 4B oars or afea Mac wa Ht Ts
7 at aHAT #1 Vet Peaks F ae Hex Pw} ew F Peparet Br area : a .
9) aren ser ae, Pret afte fear rar @, % are seca eaves ae ate arg % vee fea aT
ara Saw are Pret fate ak F wre Ai ws ara ® ade Fy; a) often: ood aqadf heise af B te arg At vet arte Bt array Tas are Pet wera TE
TAY ara H Hate F, forae aren %, gare Pre fafa we & orferae weecarefeat 4 a Here Ie Beare FTF |
awe faecht % at 2013 % araet are ® 224 fea feet, fager ws soot areal F al-at yer saat F Pere fear war atte wat ors ware wa A oars #1 art freq Ff freer Ft feats F steht ae wart arar wren |
area Trey Ft arnathres aareraret freer worerea ft aca Ft sre went FF ate a a |
(aeraTa Efe ) (310 arf arearer & fra)
fazer wit Faeer Hat

20- ’ THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)] .
. write
MT It we He tar F Set Hears & Gere we faethe wees St Cees & fre area Terese Ft acar< Hz atrraifres warwrardt after worerer At acare dhe Here far we Recht F as 2013 waae arg % 227 far fraferferr sraett oe agNT EUS At THT HOT HT UH aah ATT TTT: |
(i) aye 7% ferare 1 sat 2% art F ag aA oat FH wet eH ahterardt ee HT eH see sat feet eardt dearest arera & gat dfrerard crear F seqay Ht fast Hear g aerar wey Hea ¥ aay Hare as
Caan &, Sa caret dearest & arat wr Pater wert are sree Ft ws Her UP oe ae far aT, Tey arftaat ts treet ser arr aneare oe Patter Pear saa ay et fAfrat sear arcane } fore cardt dearest &
arerfins erdarerre % fore artrer Hi wet are ade, sarge, Farsi, rater car sftrssrcarstt % fare Sat araat Fe Sey y ora eH caret Heaney @, a Ua caret Gearsat & arat ar Pricer dh Ft Heat aN at AEF
farar wre very ear Pretcor terey Be Ta ATH sree ax Peay aT rea sa Tee F erst Hearsay Bre sardt we & fare oar & wef cart dearest fea 1
(ii) «= - aa aren wren 2 fH a Hae & aay F ale feet ane aiterers ose & eg an & oral B gat afaararé cee & Part Ht saan arerard &, at ate arger & VS waren arrard sree va were H Sra YT
_ are er .
(iii) ae arene oer & fH Arai’ Te TTWAR 10 F are F 7.5 were Kt we ae GENT Dae Fat HUT FATT HF
A aréte & ate ae are after wet oreaefts art 1 ahs we ex Ht ate ae are after ae Ft ore 3 75 :
afters F agra ax are TH |
Rees errery H, werk fore fatter wr & arfrpe sengearerhtat % xa wheat oe gear few F
aw free F ak 2013 % were arg & 224 fear fect, Reger st sieht avers F at-ar ger wftat F frorw far var ate ast ors wart we & orarfines ¥ 1 af freoor F freer Ft feehe F atts ore wart art area |
Aree Torey Ft arnathrn warorardt fterar woreree At acart Ft HT .
_ Tere FF AT A . a (weraTat Gsffz ) (a0 nf epsrar ea) ¢
MINISTRY OF FINANCE
(Department of Revenue) OS .
NOTIFICATION 7 .
New Delhi, the 28" March, 2014 ; (INCOME TAX) .
S.O. 956(E).-Whereas the annexed Agreement between the Government of the Republic of India and the
Government of the Democratic Socialist Republic of Sri Lanka for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter referred to as DTAA) signed in India on the 22" day of
January, 2013 shall enter into force on the 22" day of October, 2013, being the date of the later of the notifications after completion of the procedures as required by the laws of the respective countries for the entry into force of DTAA, in accordance with Article 30 of the said DTAA. ,
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 the provisions of DTAA annexed hereto shall be given effect to in the Union of a India with effect from the 1" day of April, 2014. ° .
. [Notification No. 23/2014/ F.No.503/8/2005-FTD-I] -
. RAJAT BANSAL Jt. Secy. _
7
; 44

[ont [wre 3(ii)] | ANT BT USA: STATE 21
OO , . Annexure .
| AGREEMENT a |
BETWEEN a |
THE GOVERNMENT OF THE REPUBLIC OF INDIA
. AND :
. THE GOVERNMENT OF THE DEMOCRATIC SOCIALIST REPUBLIC OF SRI LANKA
. FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION ~
WITH RESPECT TO TAXES ON INCOME ; ;
The Government of the Republic of India and the Government of the Democratic Socialist Republic of Sri Lanka, desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and with a view to promoting economic cooperation between the two countries, , have agreed as follows:
ARTICLE 1
PERSONS COVERED
This Agreement shall apply to persons who are residents of one or both of the Contracting States.
Article 2
TAXES COVERED ;
1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied. :
2. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes oO
_~ on gains from the alienation of movable or immovable property and taxes on the total amounts of wages or salaries paid by enterprises. - me
3. The existing taxes to which the Agreement shall apply are in particular: .
(a) in India: the income tax, including any surcharge thereon; .
(hereinafter referred to as "Indian tax"); (b) in Sri Lanka: the income tax, including the income tax based on the turnover of enterprises licensed by the Board of
Investment; (hereinafter referred to as “Sri Lanka tax” ) a ;
4. The Agreement shall apply also to any identical or substantially similar taxes on income which 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
1. For the purposes of this Agreement, unless the context otherwise requires: ae , .
: (a) the term "India" means the territory of India and includes the territorial sea and airspace above it, as well as any other .
_., maritime zone in which India has sovereign rights, other rights and jurisdiction, according to the Indian law and in
- accordance with international law, including the U.N. Convention on the Law of the Sea; ; (b) the term "Sri Lanka" means the territory of the Democratic Socialist Republic of Sri Lanka, including its land
_ territory, internal waters and territorial sea, air space above them as well as the exclusive economic zone and continental shelf where the Democratic Socialist Republic of Sri Lanka exercises or may hereafter exercise sovereign rights and jurisdiction in conformity with international law and its national legislation; : -
(c) the terms "Contracting State" and "the other Contracting State" mean the Republic of India or the Democratic Socialist |
Republic of Sri Lanka as the context requires;

22 , THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
(d) the term "person" includes an individual, a company, a body of persons and any other entity which is treated as a taxable unit under the taxation laws in force in the respective Contracting States; (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 Sri Lanka: The Commissioner General of Inland Revenue;.
(j) the term "national" means: ; (i) any individual possessing the nationality of a Contracting State; (ii) any legal person, partnership or association deriving its status as such from the laws in force in a Contracting State; -
(k) the term "tax" means Indian tax or Sri Lanka 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; .
(I) the term "fiscal year" means:
(i) in the case of India: the financial year beginning on the 1* day of April; (ii) in the case of Sri Lanka: the assessment year beginning on the 1* day of April. . —
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 Ot other criterion of a similar nature and also includes that State and any political subdivision or local authority thereof. This |.
term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that ~
State.
2. Where by reason of the provisions of paragraph | 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; oo ; |
‘ — (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 :
<" “ whichheisanationa; = an (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. 7

[art f-wrs 3(ii)] FIA Hl TATA: SATE 23
3. Where by reason of the provisions of paragraph |, 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 shal! settle the question by mutual agreement.
Article §
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. ;
2. The term "permanent establishment” includes especially: a _
(a) a place of management; : .
(b) a branch; ; (c) an office; , (d) a factory; (e) a workshop; :
(f) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources; ; (g) a farm, plantation or other place where agricultural, forestry, plantation or related activities are carried on, (h) a sales outlet ; (i) a warehouse in relation to a person providing storage facilities for others.
3. (a) A building site or construction, installation or assembly project or a drilling rig or supervisory activities in connection therewith constitutes a permanent establishment only if such site, project or activities last more than 183 days.
(b) The furnishing of services, including consultancy services, by an enterprise through employees or other personnel .
_ engaged by the enterprise for such purpose constitutes a Permanent Establishment, but only where activities of that se nature continue (for the same or connected project) within the Contracting State for a period or periods aggregating more than 90 days within any 12-month period. an
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 or display of goods or merchandise belonging to the enterprise;
. (vb) _ the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of storage or 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 collecting information, for the enterprise; (e) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; (f) the maintenance of a fixed place of business solely for any combination of activities mentioned in subparagraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character.

5. Notwithstanding the provisions of paragraphs 1 and 2, where a person - other than an agent of an independent status to whom paragraph 7 applies - is acting in a Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise, if such a person:

(a) has and habitually exercises in that State an authority to conclude contracts in the name of the enterprise, unless the
- activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of

24 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph, or Oo

(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 or for the enterprise and other enterprises which are controlling , controlled by , or subject to the same common control as that enterprise.
6. Notwithstanding the preceding provisions of this Article, an insurance enterprise of a Contracting State shall, except in
- regard to reinsurance, 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.

7. Anenterprise 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 shall 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 that other Contracting State. .
- 2. The term "immovable property” shall have the meaning which it has under the law of the Contracting State in which the
_ property in questign is 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. the working of, or :

the right to work, mineral deposits, sources and other natural resources; ships, boats and aircraft shall not be regarded as immovable property. a

3. The provisions of paragraph | of this article 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 of this article shall also apply to the income from immovable property of an . oo enterprise and to income from immovable property used for the performance of independent personal services. -

. Article 7 -
BUSINESS PROFITS , .
1. The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business as aforesaid, the profits of the 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 permatient 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. However, no such deduction shall be allowed in respect of

ty. - amounts, if.any, paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the of
| . |}
n |
I.

Cart -wars 3(ii)] ANG BT UATA : AAT 25
head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents, know-how or other rights, or by way of commission or other charges for specific services performed or for management, or, except in the case of banking enterprises, by. way of interest on moneys lent to the permanent establishment. Likewise, no account shall be taken, in the determination of the profits of a permanent establishment, for amounts charged (otherwise than toward reimbursement of actual expenses), by the permanent establishment to the head office of the enterprise or any of its other offices; by way of royalties, fees or other similar payments in.return for the use of patents, know-how or other rights, or by way of commission or other charges for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the head office of the enterprise or any of its other offices.

4. 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. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.

7. Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article.

* Article 8
SHIPPING AND AIR TRANSPORT ; ;
1. Profits derived by an enterprise of a Contracting State from the operation of aircraft in international traffic. shall be taxable only in that State. . oC
2. Profits derived in a Contracting State by an enterprise of the other Contracting State from the operation of ships in
— international traffic may be taxed in the first mentioned State, but the tax so charged shall be reduced by an amount equal ; to 50 per cent thereof. . i -
3. If the place of effective management of a shippipg enterprise is aboard a ship, then it shall be deemed to be situated in the
Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in the
Contracting State of which the operator of the ship is a resident.
4. 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 which is incidental to its international operations of aircrafts or ships shall be regarded as profits derived from the operation of such aircrafts or ships in international traffic and would be taxed subject to the provisions of paragraph 1 and 2 respectively, unless the containers are used solely within the other contracting
State. ;
5. For the purposes of this Article interest on investments directly connected with the operation of ships: or aircraft in international traffic shall be regarded as profits derived from the operation of such ships or aircraft if they are integral to the carrying on of such business, and the provisions of Article 11 shall not apply in relation to such interest.
6. 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 ; ; Lo
ASSOCIATED ENTERPRISES 7
1. Where . a (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or uo (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, _
yo oh) laa | | _ |

26 ° THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)] —
and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
2. Where a Contracting State includes in the profits of an enterprise of that State - and taxes accordingly - profits on which an enterprise of the other Contracting State has been charged to tax in that other State and the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provisions of this Agreement and the competent authorities of the
Contracting States shall if necessary consult each other.
Article 10
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 7.5 per cent of the gross amount of the dividends. The provisions
__ of 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 1 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. In 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 as 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 os profits consist wholly or partly of profits or income arising in such other State. .
Article 11 7
INTEREST
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 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 (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-Import bank of India, the National Housing a
Bank; and -
(ii) in the case of Sri Lanka, the Central Bank of Sri Lanka; or
| | ll foo,
. { a

[art 1s 3(ii)] A Fl UAT : ARTA 27
(c) any other institution the capital of which is wholly owned by the Government of that State, as may be agreed upon from time to time between the Competent authorities of the Contracting States through

exchange of letters.

4. The term "interest" as used in this Article means income from debt claims of every kind, whether or not secured by , mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures. Penalty charges for 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 ofa
Contracting State, carries on business in the other Contracting State in which the interést 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 payer 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, having regard to the debt claim for which it is paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the last mentioned amount. In such case, the excess part of the payments shall remain taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.

Article 12
ROYALTIES AND FEES FOR TECHNICAL SERVICES
1. Royalties or fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State
L 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 or discs 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 | 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 4
establishment or fixed base is situated.

28 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)] _
(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 royalties or fees for technical services, having regard to the use, right or information for which they are paid, exceeds the amount which would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the 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 paragraph 2
of 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. | sO
6: Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident. .
‘ ; Article 14 ;
. INDEPENDENT PERSONAL SERVICES : oo
1. “‘neome 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 State except in the following circumstances when such income may also be taxed in the other Contracting State: ms (a) if he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his —
... activities; in that case, only so much of the income as is attributable to that fixed base may be taxed in that other ~
State; or (b) if his stay in the other Contracting State is for a period or periods amounting to or exceeding in the aggregate 183
days in any twelve month period commencing or ending in the fiscal year concerned; in that case, only so much of
___, the income as is derived from his activities performed in that other State may be taxed in that other State.
2. The tert "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 .
oe -. DEPENDENT PERSONAL SERVICES .
“I, 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. _ 7 —

(arm []-wrg 3(ii)] Ad FT UAT: TATETCT 29
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 that other Contracting 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 that other Contracting State, and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has. in that other
Contracting 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 asa 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
1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an artiste,
_such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.
2. Where income in respect of personal activities exercised by an artiste or a sportsperson in his capacity as such accrues not to the artiste 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 artistes or sportsperson are exercised.
BL fey
3. The provisions of paragraphs 1 and 2, shall not apply to income from activities performed in a Contracting State by on
“ artistes 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 artist or sportsperson is a resident. -
"Article 18 7 |
"PENSIONS AND ANNUITIES
1. Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration and any annuities paid to a resident of a Contracting State in consideration of past employment and any annuity paid to such a resident shall be taxable only in that State.
2. The term "annuity" means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money's worth.
. Article 19 .
GOVERNMENT SERVICE , .
1. (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. - 7
_(b} However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: -
(i) is a national of that State; or -
(ii) did not become a resident of that State solely for the purpose of rendering the services.
2. (a) Any pension paid by, or out of funds created by, a Contracting State 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. ,
1406 ed/t4- 8 | a

30 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3({ii)] -
3. The provisions of Articles 15, 16, 17 and 18 shall 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.
4. For the purpose of this Article, the term “Government” shall include any State Government or local authority of either
Contracting State.
Article 20
Lo, PROFESSORS, TEACHERS AND RESEARCH SCHOLARS
1 oA professor, teacher or research scholar who is or was a resident of a Contracting State immediately before visiting the other Contracting State for the 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 Contracting State on any remuneration for such teaching or research for a period not exceeding two years from the date of his first arrival in that other Contracting State.
2. 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 Contracting State in the fiscal year in which he visits the other Contracting State or in the immediately preceding fiscal year.
3. For the purposes of paragraph | "approved institution" means an institution which has been approved in this regard by the Government of the concerned Contracting State.
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 and who is present in that other Contracting State solely for the purpose of his education or training shall, besides grants, scholarships and any payments received from sources outside that State for the purpose of his maintenance, :
- education or training, be exempt from tax in that other Contracting State on remuneration which he derives from an employment which he/she exercises in the other Contracting State if the employment is directly related to his studies.
2. The exemption available under paragraph 1 above in respect of remuneration from employment shall not exceed an ; amount equal to US$ 3000/- per annum. , ;
3. 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 arrival, for the purpose of his education or training in that oo other Contracting State. ;
Article 22 0
OTHER INCOME . ; ;
1. Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this
Agreement shall be taxable only in that State. _
2.: The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State
: independent personal services from a fixed base situated therein, and the right or property in respect of which the income’
is paid is 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, shail apply.
3... Notwithstanding the provisions of paragraphs | and 2, items of income of a resident of a Contracting State not dealt with
.-in the foregoing articles of this Convention and arising in the other Contracting State may also be taxed in that other
"State. oO

[ar Hare 3(ii)) ARG HUSA : ASTI 31
| | Article 23
METHODS FOR ELIMINATION OF DOUBLE TAXATION
1. The laws in force in either of the Contracting States shall continue to govern the taxation of income in the respective
Contracting States except when any provision to the contrary is made in this Agreement. When income is subject to tax in both Contracting States, relief from double taxation shall be given in accordance with the following paragraphs of this
Article. .
2. In India:
(a) Where a resident of India derives income which, in accordance with the provisions of this Agreement, may be taxed in Sri Lanka, India shall allow as a deduction from the tax on the income of that resident, an amount equal to the tax paid in Sri Lanka.
Such deduction shall not, however, exceed that portion of the tax as computed before the deduction is given, which is attributable, as the case may be, to the income which may be taxed in Sri Lanka.
(b) Where in accordance with any provision of the Agreement income derived by a resident of India is exempt from tax in India, India may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
' 3, In Sri Lanka:
(a) Where a resident of Sri Lanka derives income which, in accordance with the provisions of this Agreement, may be taxed in India, Sri Lanka shall allow as a deduction from the tax on the 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 the deduction is given, which is attributable, as the case may be, to the income which may be taxed in India.
(b) Where in accordance with any provision of the Agreement, income derived by a resident of Sri Lanka is exempt
_ from tax in Sri Lanka, Sri Lanka may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income.
Article 24
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 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. This provision shall not be construed as preventing a—
Contracting State from charging the profits of a permanent establishment which a company of the 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 the first mentioned Contracting State, nor as being in conflict with the provisions of paragraph 3 of Article 7.

3. Except where the provisions of paragraph | of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other
Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the.
same conditions as if they had been paid to a resident of the first-mentioned State.

4. Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State shall not be subjected in the first-mentioned State to any taxation or 7
any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected... =

5. The provisions of this Article shall apply to taxes covered by this Agreement. 7 .

32 THE GAZETTE OF INDIA : EXTRAORDINARY {PART II—SEC. 3(ii)}
Article 25 oe
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 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.
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 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 advisable in order to reach agreement to have an _
oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.
Article 26
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 to the
_ administration or enforcement of the domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as the taxation thereunder is not :
contrary to the Agreement. The exchange of information is not restricted by Articles | and 2.
2. Any information received under paragraph 1 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, the determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the. information only for such purposes, They may disclose the
-- information in public court proceedings or in judicial decisions. Notwithstanding the foregoing, information received by , a Contracting State may be used for other purposes when such information may be used for such other purposes under ot
‘ the laws of both States and the competent authority of the supplying State authorises such use. mo
3. In no case shall the provisions of paragraphs | and 2 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. .

[sm Hare 3(ii)] ARG BT UAT: TATTTT 33
- Article 27 ee
ASSISTANCE IN THE COLLECTION OF TAXES |
1. The Contracting States shall lend assistance to each other in the collection of revenue claims. 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 covered by the Agreement together with interest, 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 Contracting State and is owed by a person who, at that time, cannot, under the laws of that Contracting State, prevent its collection, that revenue claim shall, at the request. of the Competent Authority of that Contracting State, be accepted for purposes of collection by the
Competent Authority of the other Contracting State, and that revenue claim shall be collected by that other Contracting
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 Contracting State. .
4, When a revenue claim of a Contracting State is a claim in respect of which that Contracting 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 Contracting State, be accepted for purposes of taking measures of conservancy by the
Competent Authority of the other Contracting State. That other Contracting 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 Contracting State even if, at the time when such measures are applied, the revenue claim is not enforceable in the first-mentioned Contracting State or is owed by a person who has a right to prevent its collection.
5. The provisions of this Article shall be invoked on request of a Contracting State only after all permissible measures of recovery under the domestic laws of that Contracting State have been exhausted.
6. 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 Contracting State, be subject to the time limits or accorded any priority applicable to a revenue claim under the laws of that Contracting 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 Contracting State, haveany priority = = =
Oe applicable to that revenue claim under the laws of the other Contracting State. fe an —
7. Proceedings with respect to the existence, validity or the amount, of a revenue claim of a Contracting State shall only be i brought before the courts or administrative bodfes of that Contracting 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. . ;
8. 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 Contracting 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 Contracting State that is enforceable under the laws of. that Contracting State and is owed by a person who, at that time, cannot, under the laws of that Contracting State, prevent its collection, or (b). in the case of a request under paragraph 4, a revenue claim of the first-mentioned Contracting State in respect of which that Contracting State may, under its laws, take measures of conservancy with a view to ensure its collection.
- The Competent Authority of the first-mentioned Contracting State shall promptly notify the Competent Authority of the other Contracting State of that fact and, at the option of the other Contracting State, the first-mentioned.
Contracting State shall either suspend or withdraw its request.
9. In no case shall the provisions of this Article be construed so as to impose on a Contracting State the obligation:
(a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other
Contracting State; , ; (b) . to carry out measures which would be contrary to public policy (ordre public); . ae (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 practices; ne , (d) to provide assistance in those cases where the administrative burden for that Contracting, State is clearly disproportionate to the benefit to be derived by the other Contracting State. oo SO
Lie St) I4- 5 7 | :

34 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]
Article 28
LIMITATION OF BENEFITS
1. 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.

2. 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) a company incorporated in either of the Contracting States, if ; (i) the principal class of its shares is listed on a recognized stock exchange as defined in paragraph 5 of this
Article and is regularly traded on one or more recognized 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 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 individual 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 individual 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 individual residents of either of the Contracting States, or (d) A charitable institution or any 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 oe connection with a transaction entered into with the Permanent Establishment of the bank situated in either of the
Contracting States), . a

3. The provisions of Paragraph 1 and 2 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 a 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 a

.. 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. _

4. Aresident 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.
5. For the purposes of this Article the term 'recognized stock exchange’ means —
(a) in India, a stock exchange which is for the time recognized by the Central Government under Section 4 of the
* Securities Contracts (Regulation) Act,1956. . ;
“+= -() in Sri Lanka any stock exchange licensed by the Security and Exchange Commission of Sri Lanka.
(c) any other stock exchange which the Competent Authorities agree to recognize for the purposes of this Article.
6. Notwithstanding anything contained in the preceding paragraphs of this Article, any person (including individuals) 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.
.
he

(art T-wars 3(ii)] ARI BT UAGA : ARTA 35
Article 29
MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS
Nothing in this Agreement shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements.
Article 30
ENTRY INTO FORCE
1. The Contracting States shall notify each other in writing, through diplomatic channels, of the completion of the procedures required by the respective laws for the entry into force of this Agreement.
2. This Agreement shall enter into force on the date of the later of the notifications referred to in paragraph | of this Article. .
3. The provisions of this Agreement shall have effect:
(a) In India, in respect of income derived in any fiscal year beginning on or after the first day of April next following the calendar year in which the Agreement enters into force; and , (b) In Sri Lanka, in respect of income derived in any taxable year beginning on or after the first day of April next .
following the calendar year in which the Agreement enters into force.
4, The Convention between the Government of the Republic of India and the Government of the Democratic Socialist
Republic of Sri Lanka for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on
Income and on Capital signed on 27" January 1982 shall terminate and cease to have effect when the provision of this
Agreement become effective in accordance with the provisions of paragraph 3 of this Article.
Article 31
TERMINATION
This Agreement shall remain in force indefinitely until terminated by a Contracting State. Either Contracting State may terminate the Agreement, through diplomatic channels, by giving notice of termination at least six months before the end of
_. any calendar year beginning after the expiration of five years from the date of entry into force of the Agreement. In such event, the Agreement shall cease to have effect:
(a) In India, in respect of income derived in any fiscal year on or after the first day of April next following the calendar year in which the notice is given; and ’
(b) In Sri Lanka, in respect of income derived in any taxable year on or after the first day of April next following the calendar year in which the notice is given.
IN WITNESS WHERECF the undersigned, duly authorized thereto, have signed this Agreement.
‘DONE in duplicate at New Delhi, this 22 day of January, 2013, each in the Hindi, Sinhala and English languages, all texts being equally authentic. In case of divergence of interpretation, the English text shall prevail. ;
For the Government of the Republic of India For the Government of the Democratic Socialist
- Republic , of Sri Lanka (SALMAN KHURSHID) (PROF. GAMINI LAKSHMAN PEIRIS)
Minister of External Affairs Minister of External Affairs

. .

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

PROTOCOL
The Government of the-Republic of India and the Government of the Democratic Socialist Republic of Sri Lanka on signing at New Delhi on 22" January, 2013, the Agreement for the Avoidance of Double Taxation and the Prevention of

Fiscal Evasion with respect to Taxes on income have agreed upon the following provisions which shall form an integral part

of the said Agreement.

(i) In respect of paragraphs | and 2 of Article 7, it is understood that where an enterprise of a Contracting State sells goods or merchandise or carries on business. in the other Contracting State through a permanent establishment situated therein, the profits of that permanent establishment shall not be determined on the total amount received by the enterprise, but shall be determined only on the basis of that part of the receipts which is attributable to the actual activity of the permanent establishment for such sales or business. Likewise in the case of contracts for survey,

supply, services, constructions or installations, when the enterprise has a permanent establishment, the profits of such permanent establishment shall not be determined on the total amount of the contract, but shall be determined only on the basis of that part of the contract, which is effectively carried out by the permanent establishment in the
State where the permanent establishment is situated.

(ii). It is understood that in relation to this Agreement if at any time the provisions of the domestic law of a Contracting _
State are more beneficial to a resident of the other Contracting State, then such more beneficial provisions of the domestic law shall prevail over the provisions of this Agreement.

(iii) It is understood that, in respect of Article 10 on ‘Dividends’ the rate of withholding agreed to at 7.5% will be subject

to review after three years from the date the Agreement enters into force. In case this rate is not reviewed after 3
years, the agreed rate of 7.5 % will continue.

IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Protocol.

DONE in duplicate at New Delhi, this 22" day of January, 2013, each in the Hindi, Sinhala and English languages, all texts

being equally authentic. In case of divergence of interpretation, the English text shall prevail.

For the Government of the Republic of India For the Government of the Democratic Socialist oO :

; ; Republic
Mo, . of Sri Lanka (SALMAN KHURSHID) . (PROF. GAMINI LAKSHMAN PEIRIS)
Minister of External Affairs Minister of External Affairs
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