পাতা:বাংলাদেশ গেজেট, অতিরিক্ত, জানুয়ারী ২, ১৯৯৪.pdf/১৯

বাংলাদেশ গেজেট, অতিরিক্ত, জানায়ারী ২, ১৯৯৪ o Article 24 Exchange of onformation 1. The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Agreement. Any information received by a Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of the enforcement or prosecution in respect of, or the determination or appeals in relation to, the taxes covered by the Agreement. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions concerning the case to which such information relates. 2. In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation : - (a) to carry out administrative measures at variance with the laws and administrative practice of that or of the other Contracting State : (b) to supply information which is not obtainable under the laws or in the normal course of the administration of that or of the other Contracting State ; (c) to supply information which would disclose any trade, business industrial, commercial or professional secret or trade process, or information, the disclosure of which sould be contrary to public policy (ordre public). Article 25 Mutual Agreement Procedure 1. Where a person considers that the actions of one or both of the Contracting State result or will result for him in taxation not in accordance with the provisions of this Agreement he may, irrespective of the remedies provided by the domestic law of those State, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23 to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to rownlvo, the rose by mutual agreement with the competent authority of the other