AAR : Date of filing of return is relevant date to consider applicability of proviso to section 245R(2
Authority For Advance Rulings (Income Tax), New Delhi Wavefield Inseis Asa, In Re Section : 245R P.K. Balasubramanyan, J. And […]
Sec. 245R
Sec. 245R
Sec. 245R
AAR : Maintainability of advance ruling where applicant has entered into offshore supply contract with a non-resident company and question as to whether payment made under transaction was chargeable to tax under Act was already pending before authorities under Act arising out of an assessment against said non-resident
Authority For Advance Rulings, (Income-Tax), New Delhi Nuclear Power Corporation Of India Ltd., In Re Section : 245R Justice P.K.
Sec. 245R, Section 143
Delhi H.C : The assessee/petitioner is aggrieved by the rejection of its application under Section 245R(2)
High Court Of Delhi Sage Publications Ltd. U.K. vs. DCIT (IT) Circle-II (2), New Delhi Section 245R, 143 Assessment Year
Sec. 245R, Section 143
AAR- New Delhi : A question cannot be said to be already pending for adjudication before AAR unless notice under section 143(2) is issued before application seeking advance ruling is filed
Authority For Advance Rulings (Income Tax), New Delhi Ls Cable & System Ltd., Korea Hyderabad Project, In Re Section :
Sec. 245R, Section 143
AAR-New Delhi : Where return is filed but notice for assessment is issued after filing application before AAR, application is to be admitted under section 245R
Authority For Advance Rulings (Income-Tax), New Delhi Aircom International Ltd., United Kingdom, In Re Section : 245R, 143 Justice Dr.
Sec. 245R, Section 143
AAR-New Delhi : Application seeking ruling of AAR cannot be admitted when return is filed and issues raised in application are shown in return and notice under section 143(2) is issued
Authority For Advance Rulings (Income Tax), New Delhi J & P Coats Ltd., In Re Section : 245R, 143 Justice
Sec. 245R, Section 143
AAR-New Delhi : Only when issues are shown in return and notice under section 143(2) is issued, question will be considered as pending for adjudication before Income-tax Authorities
Authority For Advance Rulings (Income Tax), New Delhi Mitsubishi Corporation, Japan, In Re Section : 245R, 143 Justice Dr. Arijit
Section 139, Sec. 245R
Delhi H.C : Whether once an assessee proceeds to file a return, or take a similar step, jurisdiction of Authority for to entertain application for advance ruling on same question is taken away, because Income Tax authority concerned would then Advance Rulings seized matter, and would potentially possess a multitude of statutory powers to examine and rule on return
High Court Of Delhi NETAPP B.V. Vs. Authority For Advance Rulings Assessment Year : 2009-10 Section : 245R, 139 Ravindra
Sec. 245R
AAR : Whether the provisions of section 115JB of the Act relating to payment of minimum alternate tax (MAT) are applicable only to domestic Indian companies ?
Authority For Advance Rulings (Income-Tax), New Delhi Zd, In Re Section : 245R P.K. Balasubramanyan, Chairman, J. A.A.R. No. 1098
Sec. 245R
AAR : Whether if applicant before authority for Advance Rulings had already filed a return of income involving amount arising out of identical transaction on which a question for ruling of Authority for Advance Ruling is raised by filing an application under section 245Q(1), application before Authority for Advance Rulings will be barred by clause (i) of proviso to section 245R(2) and, hence, to be rejected
Authority For Advance Rulings, (Income-Tax) New Delhi Netapp B.V., In Re Section : 245R Justice P.K. Balasubramanyan, Chairman And V.K.
