#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
MAT U/s. 115JB of Income Tax not applicable to foreign company without presence in India
Income Tax

Income Tax
Storage and Supply of goods in India through an independent third party gives rise to fixed place permanent establishment in India
Income Tax

Income Tax
Consideration for assignment of supply agreement not taxable in the absence of Permanent Establishment in India
Income Tax

Income Tax
Services provided for purchase of goods to be exported from India may not be eligible for exemption provided under Income-tax provisions
Income Tax

Income Tax
Payments towards workshop conducted for dissemination of information which is a part of study course cannot be termed as FIS
Income Tax

Income Tax
Payments for referral services cannot be termed as fees for technical services (FTS)
Income Tax

Income Tax
Ultimate Holding Company should not be considered as beneficial owner of gains arising to Subsidiary Company on sale of investments held by such Subsidiary Company
Income Tax

Income Tax
FII’s Income from trading in futures and options is business income
Income Tax

Income Tax
Mere reimbursement of costs based on a cost sharing agreement not liable to withholding tax
Income Tax

Income Tax
Consortium members working together with independent scope not an AOP
Income Tax

Income Tax
Supply of customized software and enabling client personnel to handle the system amounts to “fees for included services” under the India-US tax treaty
Income Tax

Income Tax
Payment received on account of supply of software products to independent third party re-sellers in India not royalties but business income
Income Tax

Income Tax
Authority for Advance Ruling liberally interprets tax residency rules for returning employees
Income Tax

Income Tax
