1. States Parties shall provide assistance to each other in the collection of tax claims. This aid shall not be limited by Articles 1 and 2. The competent authorities of the States Parties may, by mutual agreement, regulate the application of this article. and, in both cases, conditions different from those which would be achieved between independent undertakings are established or imposed between the two undertakings in their commercial or financial relations, and then all profits which, without those conditions, would have been paid to one of the undertakings but which have not been incurred as a result of those conditions; can be included in the profits of that business and taxed accordingly. In duplicate in Warsaw, january 29, 2013, in Hindi; The texts are equally authentic in Polish and English. In case of discrepancy between the Hindi and Polish texts, priority is given to the English text. In exercising the powers conferred by section 90 of the Income Tax Act 1961 (43 of 1961), the Central Government shall order that all provisions of the said Protocol amending the agreements between the Government of the Republic of India and the Government of the Polish People`s Republic for the avoidance of double taxation and the prevention of tax evasion on income, in accordance with the Annex to the present action in the Indian Union from the first day of April 2015 , the first day of the financial year following the year of entry into force of the Protocol. At the request of the competent authority of a Contracting State, the competent authority of the other Contracting State may allow representatives of the competent authority of the first Contracting State to be present at the corresponding part of a tax inspection in the second State Party. .

. .