AAR

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

AAR: Mathemetical model studies constitutes ' Royalty ' under Sri Lanka treaty

Mathemetical model studies constitutes ' Royalty ' under Sri Lanka treaty, taxable under Article 12: AAR

May 16,2011

AAR: Payment for document processing services not taxable in India

Payment to UK resident for document processing services does not qualify as 'Fees for technical services' under Act and not taxable in India: Authority for Advance Ruling (AAR)

May 16,2011

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