INDO-UAE DTAA: Mere physical presence of non-resident’s vessel in territorial waters of India pursuant to hiring of vessel on Bareboat Charter terms by applicant does not, without anything more, constitute a permanent establishment

DECIDED BY: AUTHORITY FOR ADVANCE RULINGS (INCOME TAX), NEW DELHI, IN THE CASE OF: Seabird Exploration FZ, LLC, In re, APPEAL NO: AAR No. 829 of 2009, DECIDED ON JULY 23, 2010

R U L I N G

[By Hon’ble Chairman]

1. The following facts are stated by the applicant in this application for Advance Ruling under section 245Q of the Income Tax Act 1961, hereafter referred to as the `Act’

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