#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.
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Consideration for Grant of the use or consideration for right to use is Royalty
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Composite contract for installation & commissioning cannot be split to exempt profits from offshore supply of goods
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Advisory services is technical services under Article 13.4 of India-French DTAC
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Profit on sale of Compulsory Convertible Debentures taxable as interest
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Consortium formed by non-residents for bidding for a turnkey contract taxable as AOP
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AAR Implements GAAR – Held Selective share buy-back as colourable transaction
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If immovable property is situated in India, gains also taxable in India
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S. 195 -Reimbursement of Salary to Overseas Parent Company attracts TDS
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Payment received / receivable by the applicant in connection with IVTC Services are taxable as FTS
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IF applicant has taxable income in India he is required to file tax return and tax need to be withhold on payment to him -AAR
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Shares held by nominees cannot be considered as held by assessee – S. 47(iv) relief not available if Assessee do not hold 100% of subsidiary
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Payment for use of equipment is taxable as royalty and its related installation activities is taxable as FTS
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Whether tax deduction mandatory u/s. 195 on export commission paid to non-resident agent, if so, at what rate?
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