The OECD model, the UN model, the American model and the Andean model are just a few of these models. Of these, the first three are the most important and most commonly used models. However, a final agreement could be a combination of different models. Yes, yes. As a hub for international investment and as a training for large numbers of emigrants, India understood the importance of DBAA and actively followed this issue. For example, our country has 85 such active agreements. Apart from these separate international conventions, the Income Tax Act itself provides for an exemption from double taxation. This is dealt with in sections 90 and 91. In the event of a conflict, the provisions of the DBAA are binding. In India, the central government has been authorized, in accordance with Article 90 of the Income Tax Act, to enter into agreements with other countries on double tax evasion (so-called tax agreements). India has a comprehensive agreement with 88 countries to avoid double taxation, 85 of which have entered into force.  This means that there are agreed tax rates and skill rates for certain types of income generated in one country for a country of taxation established in another country. Under India`s Income Tax Act of 1961, there are two provisions, Section 90 and Section 91, that provide taxpayers with special facilities to protect them from double taxation.
Section 90 (bilateral facilitation) applies to tax payers who have paid tax to a country with which India has signed agreements to avoid double taxation, while Section 91 (unilateral relief) provides benefits to taxpayers who have paid taxes in a country with which India has not signed an agreement. Thus, India reduces both types of taxpayers. Prices vary from country to country. The Treaty must be read carefully to understand its provisions from their correct perspective. The best way to understand the DBAA is to compare it to a partnership agreement between two. In partnership, the words “part of the first part” are used and in the DBAA the words are “the other contracting state.” The words “contracting states” can also be replaced by the names of the countries concerned and the DBAA can be re-read to better understand. In this case, the company was founded in Japan. It formed a consortium with four other companies and entered into an agreement with an Indian company, Petronet LNG Ltd, for the construction of a liquefied natural gas and degassing plant in Gujarat. Each member of the consortium should receive separate payments. The contract included offshore procurement, offshore services, land supply, onshore services, construction and construction. The price was due for deliveries and offshore services in U.S.
dollars, while the price of onshore supply as well as services, construction and assembly were partly in dollars and rupees. In the event of a conflict between the provisions of the Income Tax Act or the Double Taxation Convention, their provisions apply.