AAR Delhi

Reimbursement of seconded employee salary to expatriate employees is fees for included services- AAR

In re Verizon Data Services India Private Limited (AAR Delhi)

Verizon Data Services India Private Limited (A.A.R. Nos. 865 of 2010) - The AAR held that the seconded personnel are employees of a foreign company and render managerial services to the Applicant. Hence, the payments made would be in the nature of income and would be regarded as fees for included services under the provisions of the India...

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Foreign companies to pay tax on revenue earned under seismic data acquisition and processing contracts – AAR

OHM Limited Vs. DIT (AAR Delhi)

OHM Limited v. DIT (AAR No. 935 of 2010) - Foreign firms operating in the country will have to pay tax at the existing rate of 4.223 per cent on revenue earned under seismic data acquisition and processing contracts, says a tribunal. In a ruling, the Authority of Advanced Rulings (AAR) held that foreign firms would not enjoy any leeway e...

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Taxpayer holding tax residence certificate is eligible for the India-Mauritius tax treaty benefits

In Re. D.B.Zwirn Mauritius (AAR Delhi)

Authority for Advance Ruling (AAR) in the case of D.B.Zwirn Mauritius (AAR No. 879 of 2011) (Judgment date: 28 March 2011) dealt with the issue of taxability of capital gains on sale of shares by a Mauritian entity under the Income-tax Act, 1961 (the Act) or India-Mauritius tax treaty (the tax treaty). The AAR held that the applicant, hol...

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Pendency, before a statutory forum, of a similar matter in respect to transaction with a different party is no bar to seek advance ruling

In Re. LS Cable Ltd. (AAR Delhi)

Recently, the Authority for Advanced Ruling held that pendency of a similar matter of the applicant in respect to transaction with a different party, before a statutory forum, is no bar to seek advance ruling in respect of another transaction....

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Minimum Alternate Tax (MAT) provisions not applicable to foreign companies if no physical presence in India

In re The Timken Company (AAR Delhi)

The applicant is a company incorporated in the United States and is a leading manufacturer of engineered bearings, alloys etc. The applicant has a significant shareholding in an Indian listed company, which was initially set up as joint venture with Tata Iron and Steel Company....

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AAR rules no capital gains on Part IX conversion of firm to company

In re M/s Umicore Finance Luxembourg (A.A.R. No. 797 of 2009)

This Tax Alert summarizes a recent ruling of the Authority for Advance Rulings (AAR) [A.A.R. No. 797 of 2009] in the case of M/s Umicore Finance Luxembourg (Applicant). There was a sale of shares of a company by its shareholders which had received such shares on conversion of a firm into the company, under the provisions of Part IX of the...

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