AAR: Offshore equipment supplies not taxable absent accrual in India; Revenue's Vodafone reliance 'out of place'

AAR rules that the payment of Rs. 580 cr. by the applicant (a resident company) to its French group company (‘MFPM’) for offshore supply of equipment under the Umbrella Agreement,

Jan 18,2018

AAR: No restriction on acquiring new property outside India for exemption u/s. 54 before 2014 amendment

AAR allows Sec. 54 benefit to the applicant ( an individual, a non-resident and settled in UK) on his investment in a residential house in London out of the capital

Jan 18,2018

AAR: Belgian company's lighting contract for Commonwealth Games meets fixed place-PE's 'disposal' test

AAR rules that entire consideration of USD 3.5 million received by applicant (a Belgium based company) for rendering, lighting and searchlight services to the Organizing Committee, Commonwealth Games 2010, Delhi

Jan 17,2018

AAR: Indirect transfer taxation u/s 9 not triggered on offshore share deal; Confirms treaty benefit

The Authority for Advance Rulings (AAR) rules that offshore share transfer in Germany between non-residents resulting in indirect transfer of shares held in an Indian entity is not taxable u/s

Jan 17,2018

AAR: Overseas payments by non-resident for India project-related services not taxable

AAR holds that payment by applicant (a UK company) to third party service providers outside India for services in connection with expatriate movement to India in relation to its contract with Indian

Sep 12,2016

AAR: Program-fees received by non-profit US University not taxable as FTS/business income

AAR rules that program fees received by the Regents of the University of California (‘applicant’) from its Indian counterpart for holding management programs (for training senior executives) not taxable in

Sep 09,2016

AAR: Offshore supply taxable; Cites composite contract , sale conclusion in India

AAR rules that entire  contract revenue arising to a Singaporean co. (applicant, a sub-contractor) from L&T towards supply of goods and rendition of services, taxable in India; In connection with

Sep 09,2016

AAR: Product promotion services payment by Indian Pharma-company to overseas subsidiary not FTS

AAR rules that service fee payable by Dr Reddy’s Laboratories Limited (‘applicant’) to its Russian subsidiary (‘DRL Russia’) under the Service Agreement for providing product promotion services, not FTS either

Sep 09,2016

AAR: Tech Mahindra - AT&T Mauritian share-deal exempt under treaty; observes 'control & management' outside India

AAR holds that Mahindra-BT Investment (Mauritius) (i.e. applicant), not liable to tax in India in respect of transfer of  shares in Tech Mahindra Ltd. (‘TML’) to AT&T International USA carried in

Sep 06,2016

AAR: Allows Mauritius DTAA relief; Distinguishes 'permitted transferee' fact-pattern from Aditya-Birla ruling

AAR rules that capital-gains arising to a Mauritian company (applicant and wholly owned subsidiary of a Japanese bank, being a promoter and settlor of Indian mutual funds) on transfer of

Aug 31,2016