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

AAR: No tax on Satyam's Court ordered multi-million dollar 'penalty' payment in USA 

AAR rules penalty payment by Satyam (applicant) to US Govt. not liable to TDS u/s 195; AAR notes that pursuant to complaint filed by the US SEC (Securities & Exchange

Dec 10,2015

AAR: Chinese company's procurement services taxable as FTS, actual performance in India irrelevant 

AAR holds that receipt for services rendered in connection with procurement of goods by the Applicant (a Chinese subsidiary of an Indian company) taxable @10% on gross basis, as FTS

Oct 12,2015

AAR: Management & procurement service payments to UK co not FTS, absent 'make-available' 

AAR rules that amount received by applicant (a UK co.) for providing 'management services' and 'procurement services' to its Indian affiliate not fees for technical services (FTS) under Article 13

Aug 03,2015

AAR: E-learning revenues taxable as 'royalty'; Rejects 'copyrighted article' plea for software license 

AAR holds payment received by applicant (an Ireland co. engaged in providing e-learning courses) from an Indian distributor for sale of products to Indian end-users (permitted to access the e-learning

Aug 03,2015

AAR: Remuneration to Sri Lankan sales executive not FTS, not taxable in India 

AAR holds Oxford University Press (a publication house in India of Oxford University UK) not liable to withhold tax on remuneration paid to non-resident sales executive in Sri Lanka; Payment

May 23,2014

AAR: AAR follows 'Cairn' ruling; Allows lower tax rate on listed share sale 

AAR holds Pan-Asia iGate Solutions (a Mauritian company purchasing Patni's shares from non-resident US seller) to withhold tax @ 10%; Non-resident seller eligible for lower tax rate of 10% on

May 23,2014

AAR: 'Make available' import into India-France DTAA Protocol denied; Services taxable as FTS 

AAR holds payment by Streia (India) Ltd. (applicant) to Groupe Steria, France for management services taxable as Fees for Technical Services (‘FTS’) under India-France DTAA, liable to tax withholding u/s

May 16,2014