March 2010

Section 9, Sec. 9(1)(vi), Section 195

AAR : Whether pursuant to the cost contribution agreement proposed to be entered by the applicant with ABB Research Ltd., Zurich (“ABB Zurich”), the payments to be made to ABB Zurich, representing the applicant’s share of the costs incurred towards basic research and development (“R&D”) activities, constitutes “income” in the hands of ABB Zurich within the meaning of the term in s. 2(24)

Authority For Advance Rulings ABB Ltd., IN RE Section 9(1)(vi), 195, DTAA between India & Switzerland, art. 7, DTAA between

Sec. 37(1), Section 43A

S.C : Whether on the facts and circumstances of the case, the additional liability arising on account of fluctuations in the rate of exchange in respect of loans taken for revenue purposes could be allowed as deduction under s. 37(1) of the IT, Act, 1961 (for short ‘the Act’) in the year of fluctuation in the rate of exchange or whether the same is allowable only in the year of repayment of such loans ?

Supreme Court Of India Oil & Natural Gas Corpn. Ltd. vs. CIT Section 37(1), 43A Asst. Year 1991-92, 1992-93, 1993-94,

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