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

AAR: Foreign cos. amalgamation survives taxability despite India branch; Non-discrimination clause the saviour

AAR rules that capital gains arising on amalgamation of a non-resident company (‘SSBS’) having India branch, with itsgroup company (applicant, an Italian based bank), not  taxable,  invokes non-discrimination clause under Article

Aug 30,2016

AAR: Coring services taxable u/s44BB at concessional rate; Relies on ONGC (SC) ruling

AAR rules that consideration received by the applicant (a UK company) towards provision of coring services under a sub-contract, taxable at concessional rate u/s 44BB (special provision for companies engaged

Apr 18,2016

AAR: Procurement services for sourcing from UK not royalty / FTS under treaty

AAR rules that fees received by applicant (a UK company) for rendering 'supply management' services to its Indian group company, neither FTS nor royalty under India-UK DTAA; AAR notes that

Jan 22,2016

AAR: Mauritius to Singapore share transfer driven by "operational-excellence" motive, dismisses tax-avoidance charge

AAR rules that capital gains arising on proposed transfer of Indian group company’s shares by applicant (a Mauritian company) to its Singaporean affiliate not taxable in India, grants India-Mauritius treaty

Jan 21,2016