#Advance Ruling
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Withholding tax not applicable on interest payable to Company having no PE in India under India-Sweden tax teaty

Payments for sale of software taxable as ‘Royalty’ under Article 12 of the India-Japan tax treaty

Date of filing of the return is relevant date to consider the applicability of the proviso to section 245R(2) of the Act

Authority for Advance Rulings (Income-tax) – FAQs

In Re NetApp B.V. – Filing of the return is the relevant date to consider the applicability of the proviso to s. 245R(2)

Payments received by the applicant from the distributor for sale of software product is in the nature of royalty

Business support services of advisory nature under a cost contribution agreement are consultancy services liable to tax withholding

Income-tax Authorities have no jurisdiction to tax payment made outside for supplies taking place outside the country

Business income accruing or arising to the applicant can be taxed in India only in respect of such operations carried out in India – AAR

Re Foster Wheeler France SA – Date of filing of the return is the relevant date to consider the applicability of the proviso to section 245R(2) of the Act

AAR – WaveField Inseis ASA – Date of filing of the return is relevant to consider applicability of proviso to section 245R(2)

ARA can not be accepted if question raised in application is already pending before any authority

Business Support Services / financial services not in the nature of technical services within the meaning of Article 12.5(b) of the DTA between India and the Netherlands

Advance Ruling – Payment for support service taxable as Fees for Technical service under India-Netherlands DTAA
Explore the latest Advance Ruling updates on TaxGuru, including relevant legal provisions, notifications, circulars, case laws, compliance developments and expert analysis. This page brings together important developments and practical guidance to help taxpayers, businesses and professionals stay informed and understand the regulatory and commercial implications of changes.
