ADEN RULES, 1953

76. Income-tax (Double Taxation Relief) (Aden) Rules, 1953 - Present position thereunder
1. In exercise of the powers available under section 49A of the 1922 Act, the Government of India had
issued a Notification dated 24-3-1953 called the Income-tax (Double Taxation Relief) (Aden) Rules,
1953 providing for grant of relief in respect of income on which tax has been paid both in India and in
Aden. These Rules being consistent with the corresponding provisions of the 1961 Act, continued to be
operative by virtue of the provisions contained in section 297(2)(k).
2. The Government of the Peoples' Democratic Republic of Yemen (formerly Aden) has, however, stated
that the Agreement on the basis of which the above Rules were applicable is no longer binding on it after
November 30, 1967, the date of attainment of independence by it. Thus, there is no subsisting agreement
between India and Aden for the avoidance of double taxation of income after November 30, 1967.
3. The cases of Indian residents will, therefore, be covered by the provisions for grant of unilateral relief
under section 91 of the 1961 Act. This will be applicable in respect of the assessment years commencing
from the assessment year immediately following the financial year in which Aden attained
independence. Thus, the provision for unilateral relief will become applicable in the case of income in
the Peoples' Democratic Republic of Yemen for and from the assessment year 1968-69.
Circular : No. 171 [F.No. 11(26)/69-FTD-1], dated 8-7-1975.
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