#AAR Rulings
Log in to FollowRuling passed by Authority for Advance Rulings Customs , Central Excise & Service Tax. The Authority for Advance Rulings consists of a Chairman who is a retired Judge of the Supreme court and two members of the rank of Additional Secretary to the Government of India, one each from the Indian Revenue Service and the Indian Legal Service.
Income Tax
Income Tax
AAR – Substance over form overlooked, Treaty shopping upheld, reliance placed on azadi bachao andolon case
Income Tax
Income Tax
AAR – subsidiary created for Indian business is PE of foreign applicant company as well as its group companies in India
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
Consortium formed by non-residents for bidding for a turnkey contract taxable as AOP
Income Tax
Income Tax
AAR Implements GAAR – Held Selective share buy-back as colourable transaction
Income Tax
Income Tax
