"31 January 2016" Archive - Page 2

Transfer of shares of Indian company to Singapore Company, by a Mauritius company having no PE, not taxable in India- AAR

Dow AgroSciences Agricultural Products Ltd, Mauritius, In re (Authority for Advance Rulings)

Authority for Advance Rulings held In the case of Dow AgroSciences Agricultural Products Ltd, Mauritius that the Article 13 of the Indo-Mauritius DTAA which deals with the taxation of capital gains is not applicable in the present case....

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India- Singapore DTAA – Installation project less than 183 days not constitute PE, income not taxable in India– AAR

Tiong Woon Project & Contracting (Pte) Ltd. Singapore, In re (Authority for Advance Rulings)

Authority for Advance Rulings held In the case of Tiong Woon Project & Contracting (Pte) Ltd. that the department has correctly provided a positive response that because the project was continued in India only for 178 days in a fiscal year...

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India- Ireland DTAA: Transfer of exclusive rights of copyright in computer software, not mandatory to classify receipts as royalty: AAR

SkillSoft Ireland Limited., In re (Authority for Advance Rulings)

Authority for Advance Rulings held In the case of SkillSoft Ireland limited that in the case of Synopsis International Old Ltd. 212 TAXMAN 454 (Kar), high court held that merely because the words non-exclusive and non-transferrable are used in the license agreement, it does not take away the software out of definition of copyright. ...

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Penalty on Indian company as per US Court, not liable to TDS u/s 195 – AAR

Satyam Computer Services Ltd., In re (Authority for Advance Rulings)

Authority for Advance Rulings held In the case of Satyam Computer Services Ltd., that it is trite law that unless the payment made attracts the tax under the Income Tax Act, there would be no liability to deduct tax under Section 195 of the Income Tax Act. ...

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India- UK DTAA –Routine managerial services not in nature of technical services, not makes available any technical knowledge having enduring benefits – AAR

Measurement Technology Limited UK, In re (Authority for Advance Rulings)

Authority for Advance Rulings held In the case of Measurement Technology Limited, UK that the services under agreement No.1 relate to review by Group operation Director and general guidance given by him on financial, operational, human resource, setting up targets and performance appraisal related matters...

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India- UK DTAA – Supply Management Services by UK company not in the nature of fee for technical services or royalties – AAR

Cummins Limited UK, In re (Authority for Advance Rulings)

Authority for Advance Rulings held In the case of Cummins Limited, UK that the agreement shows that the CTIL, a company incorporated in India is working with the applicant only to ensure market competitive pricing from the suppliers....

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