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CS Professional · Advanced Direct Tax Laws and Practice · Double Taxation Avoidance Agreement (DTAA)

Under the Income-tax Act, 2025 (applicable from June 2027), who may enter into an agreement with the Government of a foreign country for relief from double taxation under Section 159(1)?

The Central Government may enter into such agreements under Section 159(1) of the Income-tax Act, 2025, with any other country or specified territory, and may notify provisions needed to implement them. Tax authorities and the RBI have no power to do so.

  1. AThe Central GovernmentCorrect
  2. BThe Central Board of Direct Taxes acting independently of the Government
  3. CThe Reserve Bank of India
  4. DAny Principal Chief Commissioner of Income-tax

Explanation

Section 159(1) empowers the Central Government to enter into an agreement with the Government of any other country or specified territory and to notify provisions for implementing it. The other bodies named have no such treaty-making power under this section.

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