AAR

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

AAR: Rejects splitting revenues between offshore-onshore activities,taxes entire FPSO contract revenues u/s 44BB

 AAR rules that consideration received  by applicant (a Norwegian company ) for on-board fabrication and installation of  ‘Floating Production Storage and Offloading’ (FPSO) facility  under ‘Change Order’ with Reliance (‘RIL’)

Jan 21,2016

AAR: Disagrees with earlier ruling, Satyam’s settlement payments to US Fund, capital receipt

Pursuant to HC’s remand, AAR rules that Satyam’s class action suit settlement payments to US Settlement Fund, capital in nature, not chargeable to tax in India; In first round of

Jan 20,2016

AAR: Satyam's settlement payments to Aberdeen Funds not income; Rejects 'surrogatum' principle application

AAR rules that settlement payments by Satyam & PwC to Aberdeen Funds US & UK ('applicants') in capacity of trustees for investors' claims, a capital receipt, not taxable in India;

Jan 20,2016

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