Courts: Advance Rulings
4,639 articlesIncome Tax
Income Tax
Gift by company to subsidiary are dubious & not tax neutral – AAR
Income Tax
Income Tax
It is mandatory for foreign company to file return of income to take benefit of DTAC – AAR
Income Tax
Income Tax
Beneficial ownership not prevails over legal ownership to tax gain on sale of shares -AAR
Income Tax
Income Tax
AAR – Substance over form overlooked, Treaty shopping upheld, reliance placed on azadi bachao andolon case
Income Tax
Income Tax
A subsidiary created for Indian business is PE of foreign parent
Income Tax
Income Tax
Composite contract cannot be split to exempt profits from offshore supply of goods
Income Tax
Income Tax
DTAA between India & USA – contract for repair and overhauling services of turbines – whether Fees for Technical Services
Income Tax
Income Tax
Subscription fee received for social media monitoring and market intelligence services taxable as Royalty
Income Tax
Income Tax
Contribution towards costs of research / for the use of process or formula is Royalty
Income Tax
Income Tax
Consideration for Grant of the use or consideration for right to use is Royalty
Income Tax
Income Tax
Composite contract for installation & commissioning cannot be split to exempt profits from offshore supply of goods
Income Tax
Income Tax
Advisory services is technical services under Article 13.4 of India-French DTAC
Income Tax
Income Tax
Profit on sale of Compulsory Convertible Debentures taxable as interest
Income Tax
Income Tax
