Advance Rulings

No capital gains on conversion of partnership into private limited company irrespective of subsequent change in the shareholding : AAR

Umicore Finance Luxembourg (Authority for Advance Rulings)

No capital gains are accrued or arisen at the time of conversion of partnership into a private limited company under Part IX of the Companies Act, irrespective of subsequent change in the shareholding of such company [Umicore Finance Luxembourg (AAR No. 797 of 2009)]....

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Taxability of Non-resident on services rendered in India on purchase – AAR

Aramco Overseas Company B.V. (Authority for Advance Rulings)

This Article summarizes a recent ruling of the Authority for Advance Rulings (A.A.R. No. 825 OF 2009) in the case of Aramco Overseas Company B.V. (Applicant) on the issue of taxation of procurement support services rendered by the Indian liaison office (Indian office) of the Applicant....

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Payment made in pursuance of Cost Contribution Agreement by various entities of a Group in the R & D activities carried out centrally would not be liable to tax in India: AAR

ABB Limited (Authority for Advance Rulings)

ABB Limited (applicant), an Indian company, has various business divisions such as power products and systems, automation systems, process automation and robotics systems. The appellant is a part of the ABB Group, which is a leader in power and automation technologies that enable utility and industry customers to improve performance while...

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CAE Flight Training Institute (CFTI) is Liable to Service Tax – Authority for Advance Ruling

M/S Cae Flight Training (I) Pvt Ltd (Authority for Advance Rulings)

CFTI cannot be considered as an institute or establishment which is specifically excluded from the definition of "commercial coaching and training centre" under section 65(27) of the Finance Act, 1994; it also cannot be considered as a "vocational training institute" for the purpose of exemption from service tax under the category of "com...

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An Applicant cannot seek adjudication on merits at any time he wants, after having maintained steadfast silence throughout the earlier proceedings

Yongnam Engineering & Construction (Pvt) Ltd., In Re. (Authority for Advance Rulings)

On the facts and circumstances of this case, we do not think that the proceedings in connection with the earlier application shall now be reopened and a decisive answer to the question should be given at this stage....

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Advance Ruling on taxability of income from offshore supplies

Joint Stock Company Foreign Economic Association “Technopromexport” (Authority for Advance Rulings)

Hence, no income from offshore supplies accrues or arises or can be deemed to accrue or arise to the Applicant in India under the Indian Tax Law (ITL). The AAR also ruled that the Applicant does not have a Permanent Establishment (PE) in relation to offshore supplies. Therefore, no part of income from offshore supplies can be said to be t...

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Whether income from referral services amount to fees for technical services – whether in absence of a PE, same could be taxed in India

Re. Real Resourcing Limited (Authority for Advance Rulings)

AAR Ruling: Referral fee received from an Indian based recruitment agency by a non-­resident is not liable to tax in India in view of the provisions of India-UK Double Taxation Avoidance Agreement [Real Resourcing Limited (AAR No. 828 of 2009)]....

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Fees received on assignment of contractual rights not taxable: Authority of Advance Ruling

M/s Laird Technologies India Pvt. Ltd. (Authority for Advance Rulings)

The AAR held that the fee received by US Co from the Applicant is in the nature of business profits of US Co and the same is not taxable in India in the absence of US Co constituting a permanent establishment (PE) in India under the India-US tax treaty (Tax Treaty). Further, the Applicant is not required to withhold taxes under the Indian...

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Taxability of capital gains on transfer of shares of a wholly owned Indian subsidiary by a non resident parent company to a non resident

KSPG Netherlands Holding B.V., In Re. (Authority for Advance Rulings)

KSPG Netherlands Holding B.V. (applicant), is a company incorporated in Netherlands on November 6, 2008 with its registered office in Amsterdam. PG India is the private limited company incorporated under the Companies Act, 1956 on October 26, 2006, which was held by Pierburg GmbH until November 2008. During November 2008, Pierburg GmbH...

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Demarcated space made available in the warehouse by logistics service provider constitutes fixed place of business

Seagate Singapore International Headquarters Pvt. Ltd. In Re. (Authority for Advance Rulings)

Seagate Singapore International Headquarters Pvt. Ltd. (applicant) was engaged in the business of manufacture and sale of Hard Disk Drives (disks). It has been supplying disks to Original Equipment Manufacturers (OEMs) in India. In order to minimize the delays in the procurement of inputs from the applicant, the OEM proposed to put in pla...

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