AAR

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

AAR: Interprets residence condition; 182 days extension restricted to year of leaving India 

For qualifying as Indian resident, extension of period for Indian stay from 60 days to 182 days under Expl. (a) to Sec. 6(1) for person leaving India for employment, applicable

Feb 21,2014

AAR: Rejects application based on mere transaction "intention"; Subsidiary must exist in "reality" 

AAR rejects application by UAE company (‘applicant’), holds there is no ‘transaction’ or ‘proposed transaction’ of applicant with Indian companies u/s. 245N(a)(i); ‘Transaction’ or ‘proposed transaction’ should not be mere

Feb 15,2014

AAR: Discusses PE , business connection test; Holds Booz India as Permanent Establishment 

AAR holds Booz India as PE of various overseas Booz Group entities; Various factual aspects highlighted by Revenue support its contention that PE does exist, concludes AAR; Revenue contended that

Feb 14,2014

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