#Advance Ruling
Log in to FollowTo facilitate foreign investment into the country a number of steps have been taken by Government of India in the past. Setting up an Authority for Advance Rulings (Central Excise, Customs & Service Tax) to give binding rulings, in advance, on Central Excise, Customs and Service Tax matters pertaining to an investment venture in India is one such measure. The legal provisions of Advance Rulings were introduced through the Finance Acts of 1998, 1999 and 2003.
Income Tax
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
A subsidiary created for Indian business is PE of foreign parent
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
If immovable property is situated in India, gains also taxable in India
Income Tax
Income Tax
S. 195 -Reimbursement of Salary to Overseas Parent Company attracts TDS
Income Tax
Income Tax
