AAR

AAR: Sec 44BB is specific provision, which would prevail over general provision in sec 9(1)(vii)

Sec 44BB is specific provision, which would prevail over general provision in sec 9(1)(vii): AAR

Nov 09,2011

AAR: Amounts falling u/s 44BB excluded from purview of ‘royalty’ u/s 9(1)(vi)

Amounts falling u/s 44BB excluded from purview of ‘royalty’ u/s 9(1)(vi); Once sec 44BB is attracted, income cannot be computed as per any other special provision: AAR

Nov 09,2011

AAR: Cites McDowell, Ramsay principles; Holds part compensation on Satyam legal suit settlement taxable as royalty

Compensation towards damages, on account of assignment of imperfect title in patent and cost of litigation, is ‘capital receipt’ not subject to tax; payment for use of patent in software

Oct 18,2011

AAR: Software payments taxable as Royalty

Payment for use of ‘Licensed Program’ taxable as Royalty; tax withholding provisions u/s 195 attracted: AAR

Oct 04,2011

AAR: AAR rejects payee's application as similar question pending before AO in payer's assessment

The AAR has rejected application by payee as questions raised covered in the assessment of payer entity. AAR observed that the question raised need not necessarily be subject matter of assessment

Sep 21,2011

AAR: AAR rejects applications on questions pending before AO

Issues raised in AAR application covered in assessment; AAR rejects the application

Sep 21,2011

AAR: Sourcing from India by liaison office constitutes PE

Purchasing activity alongwith 'quality control and getting the goods manufactured as per own specification' by liaison office constitutes PE: AAR

Aug 10,2011

AAR: DTAA to govern taxability after shift of tax residence

Tax liability governed by Indo-Norway DTAA after shift of managerial control & tax residency to Norway; Amount collected as service tax to be included while determining taxable income u/s 44BB:

Aug 03,2011

AAR: AAR - ‘Off-shore supplies’ not taxable in hands of non-resident

Non-resident assessee not liable to tax in respect of off-shore sales: AAR

Aug 02,2011

AAR: NRs not entitled to concession​​al rate of 10% on LTCG

Non-Resident not entitled to concession​al rate of 10% on LTCG on off-market share sale; Earlier decision in Timken overruled: AAR

Aug 02,2011

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