With reference to India's decision to levy an equalization tax of 6% on online advertisement services offered by non-resident entities, which of the following statements is/are correct? 1. It is introduced as a part of the Income Tax Act. 2. Non-resident entities that offer advertisement services in India can claim a tax credit in their home country under the "Double Taxation Avoidance Agreements". Select the correct answer using the code given below:

The correct answer is (d) because the Equalization Levy was introduced as a separate chapter in the Finance Act, 2016, rather than as an amendment to the Income Tax Act, 1961. Since it is not classified as an income tax, non-resident entities cannot claim tax credits in their home countries under Double Taxation Avoidance Agreements (DTAA), rendering both statements incorrect. The most tempting error is assuming it falls under the Income Tax Act due to its nature, but it was intentionally kept separate to bypass treaty restrictions that limit taxation of companies without a physical permanent establishment. The core concept tested is the taxation of the digital economy and India's response to Base Erosion and Profit Shifting (BEPS).