Definition elucidating

With the recently released fifth edition of the Nearly 80% of clients seen in community mental health clinics have experienced at least one incident of trauma during their lifetime, representing roughly five out of every six clients (Breslau & Kessler, 2001).Over the past 15 years, between increases in school and community violence in the United States and unrelenting wars overseas, overt exposure to traumatic events has become an epidemic.Meaning and definitions of elucidation, translation in Marathi language for elucidation with similar and opposite words.Also find spoken pronunciation of elucidation in Marathi and in English language.

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It needs to be evaluated whether the proposed amendment would now be applicable to refer to definition prescribed under the Act also where under the judicial precedence, it is consistently held that wider definition under the Act cannot be read into treaty unless the treaty is amended.

Double Taxation Avoidance Agreement (DTAA) is bilateral economic agreement between two nations aiming to avoid or eliminate double taxation of the same income in two countries.

Under the existing provisions of section 90 of the Income Tax Act (the Act), any term used but not defined under the Act or in the DTAA entered into between Government of India and Government of country outside India u/s 90(1)/90A(1) shall have meaning assigned to it in the notification issued by the Central Government in the Official Gazette in this behalf, unless the context otherwise requires, provided the same is not inconsistent with the provisions of the Act or the agreement.

It is pertinent to note the observations of Hon'ble Supreme Court in the case of Sedco Forex International Drill Inc. CIT [2005] 279 ITR 310 (SC), in which the Supreme Court reaffirmed the law and held that if an explanation is in its nature clarificatory, then the Explanation must be read into the main provision with effect from the time that the main provision came into force.

But if it changes the law it is not presumed to be retrospective, irrespective of the fact that the phrases used are 'it is declared' or 'for the removal of doubts'."Also, Andhra Pradesh High Court in the case of Sanofi Pasteur Holding SA observed that the retrospective amendments which are not fortified by a non obstante clause expressed cannot override tax treaties.

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