Section 1993(4) in The Agreement Between the Government of India and Government of Afghanistan for avoidance of Double Taxation of income of enterprises operating aircraft.
(4)The exemption provided for in paragraphs (1), (2) and (3) above shall have effect in relation to the income derived from the operation of aircraft on or after the 26th day of January, 1952, on which date the Agreement relating to air services was signed between India and Afghanistan.In case any tax on income relatable to the aforesaid period has been recovered by either Government as of the date of this Agreement, the same shall be refunded by that Government on an application to be made in this behalf within twelve months of the said date by the airlines of India or the airlines of Afghanistan as the case may be.