AAR

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

AAR: Income from chartering offshore oil service vessels taxable at lower rate of 4.22%

Receipts from chartering of offshore oil service vessels covered u/s 44BB and taxable at lower rate of @ 4.22%

Jul 20,2011

AAR: Employee deputation taxable as FTS under IT Act and Treaty

Salary reimbursement to parent company for employees deputed to Indian subsidiary taxable as ‘managerial services’ under India-US treaty: AAR 

May 31,2011

AAR: Bill discounting income not taxable as ' interest '

Bill discounting income to US Company not taxable as ' interest ' under Act and India - US treaty, Bill discounting between group entities does not ‘prima facie’ involve tax

May 25,2011

AAR: Seismic data income taxable at lower rate of 4% u/s 44BB

Income from seismic data acquisition and processing services relating to oil exploration taxable u/s 44BB; Applicable tax rate of 4% (plus surcharge and cess) - AAR

May 17,2011

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