Indo-Mauritius DTAA – Applicant is not liable to be taxed in India on proposed transfer of its shares in an Indian Company to its wholly owned subsidiary company in India

DECIDED BY: AUTHORITY FOR ADVANCE RULINGS (Income Tax), New Delhi, IN THE CASE OF: Praxair Pacific Ltd., In re, APPEAL NO: AAR/855/2009, DECIDED ON July 23, 2010 RULING (By Shri V.K.Shridhar) This application for advance ruling has been filed by a non-resident company under section 245Q(1) of the Income-tax Act, 1961(hereinafter referred as Act). The following facts are stated in the application. 2. The applicant, Praxair Pacific Limited, is a company incorporated in Mauritius and is a tax resident of Mauritius. The applicant has a wholly owned subsidiary company in India, Praxair India Pvt. L...