#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
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AAR recommends reconsideration of RST’s ruling on availability of relief u/s. 47(iv)
Income Tax
Income Tax
No capital gain on indirect transfer of Indian shares if no consideration accrued to transferor
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Income Tax
Income taxable under both FTS and PE would be taxable as FTS – AAR
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Income Tax
Tax need to be withheld if payer has right to terminate ‘secondment’ & not ’employment’
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Income Tax
Gift by company to subsidiary are dubious & not tax neutral – AAR
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Income Tax
It is mandatory for foreign company to file return of income to take benefit of DTAC – AAR
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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
AAR – subsidiary created for Indian business is PE of foreign applicant company as well as its group companies in India
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Income Tax
A subsidiary created for Indian business is PE of foreign parent
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Income Tax
Composite contract cannot be split to exempt profits from offshore supply of goods
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Income Tax
DTAA between India & USA – contract for repair and overhauling services of turbines – whether Fees for Technical Services
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Income Tax
Subscription fee received for social media monitoring and market intelligence services taxable as Royalty
Income Tax
Income Tax
