Double Taxation Agreement

73.	Scope.
74.	Alienation of property.
74.1	Sale, meaning of.
74.1-1	Compelled sale.
74.1-2	When sale of immovable property is said to be completed.
74.1-3	When sale of building constructed by a building contractor is said to be complete.
74.1-4	Hire-purchase transaction, whether sale.
74.1-5	Leasing transaction, whether sale.
74.2	Lease.
74.2-1	Lease and licence.
74.2-2	Lease and sale.
74.3	Exchange.
74.4	Allowing possession in part performance of contract, whether alienation.
74.4-1	Allowing possession.
74.4-2	Part performance.
74.5	Agreement or arrangement which has the effect of transferring or enabling enjoyment of property is deemed transfer.
74.5-1	Contribution by a partner his individual property as his capital in the firm, whether; transfer.
74.5-2	Partner’s receiving property on dissolution of firm.
74.5-3	Copartner throwing property in hotchpot of family - Whether transfer.
74.5-4	Unequal partition of properties of Hindu undivided family amounts to transfer.
74.5-5	Family arrangement, whether transfer.
74.6	Release.
74.7	Disclaimer.
74.8	Alienation of shares of a company in liquidation.
74.9	Redemption of bonds.
74.10	Amalgamation of companies.
74.11	Dissolution of the firm.
75.	Property.
75.1	Movable property.
75.1-1	Personal effect.
75.2	Immovable property.
75.2-1	Movable property is immovable property if embedded to the earth.
75.2-2	Sale of business as a whole for slump price, whether transfer of immovable property.
75.2-3	Rights in land, building, part of building, machinery whether immovable property.
76.	Alienation of business enterprise as a whole of permanent establishment or fixed base.
76.1	‘Force of attraction’ is not applicable.
77.	Alienation of ships or aircraft.
78.	Alienation of shares of a company.
79.	Alienation of interest in partnership.
80.	Alienation of shares representing substantial participation in a company.