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Advance Ruling on nature of receipts derived by an Australian company from ONGC
Case Law Details
- Case Name
- In re Worley Parsons Services Pty. Ltd., (Authority for Advance Rulings- Income Tax)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- Advance Rulings
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RELEVANT PARAGRAPH
3. The applicant contends that the services under various contracts except contract no. 5 cannot be brought within the sweep of `royalties’ as defined in Art. XII.3 of the Double Taxation Avoidance Agreement (hereinafter referred to as `DTAA’ or `Treaty’), that there was no permanent establishment in India except in relation to Contract no.6 and that royalty income in respect of the contract no. 5 has to apportioned in such a manner that only income attributable to the Indian operations is taxed in India. Though initially in the applicatio...
