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Income from investment in Trust by ADIA is exempt in terms of India-UAE DTAA
Case Law Details
- Case Name
- Abu Dhabi Investment Authority Vs Authority for Advance Ruling (Bombay High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Bombay High Court
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Abu Dhabi Investment Authority Vs Authority for Advance Ruling (Bombay High Court)
Facts- ADIA files ROI in India disclosing income falling within the scope of section 5(2). However, in view of exemption available in terms of India-UAE DTAA, ADIA reports NIL taxable income.
AAR denies the benefit of India-UAE DTAA benefit to ADIA in respect of income accruing on the investment made or proposed to be made by Green Maiden A 2013 Trust which was established by ADIA and ETL.
Conclusion-
ADIA is the sole beneficiary of the trust, the income assessed in the hands of the trustee wil...
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