Sec. 5(2)

Section 5, Sec. 44BB, Sec. 5(2), Sec. 9(1)(i), Sec. 9(1)(vi), Section 9

AAR H.C : Whether sum paid by the applicant to the vessel providing companies (‘VPC’) under global usage Bareboat Charter Agreements (‘BBC agreements’) could be said to accrue or arise or deemed to accrue or arise in India under the provisions of the IT Act, 1961 (‘Act’) and therefore subject to withholding tax in India ?

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Authority For Advance Rulings Seabird Exploration FZ, LLC, IN RE Section 5(2), 9(1)(i), 9(1)(vi), 44BB P.V. Reddi, J., Chairman; J.

Sec. 5(2), Sec. 9(1)(i), Section 5

AAR : Whether the income derived by the applicant, a company incorporated in and tax resident of Panama, from the transfer of documents containing know-how and technical information, outside India, to EAC Nutrition Ltd. A/s, a corporation incorporated under the laws of Denmark, under the Sale and Purchase of Technology Agreement dt. 30th Nov., 2002 would be taxable in India having regard to the provisions of the IT Act, 1961 ?

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Authority For Advance Rulings Pfizer Corporation, In Re Sections 5(2), 9(1)(i) Syed Shah Mohammed Quadri, J., Chairman; K.D. Singh &

Sec. 5(2), Sec. 9(1)(i), Sec. 9(1)(vi), Sec. 9(1)(Vii)

Karnataka H.C : Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the engineering fees received/receivable by the assessee was in the nature of fees for technical services in accordance with the definition of “fees for technical services” as given in cl. (4) ofthe art. VIIIA of the amended DTAA between the Republic of India and the Federal Republic of Germany?

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High Court Of Karnataka AEG Aktiengesllschaft vs. CIT Sections 5(2), 9(1)(i), 9(1)(vi), 9(1)(vii), 90(2), DTAA between India and Germany ART.

Sec. 5(2), Sec. 9(1)(i), Sec. 9(1)(Vii), Section 9

Andhra Pradesh H.C : Whether, on the facts and in the circumstances of the case, the Tribunal was correct in law in holding that the contract/agreement between the non-resident and Midhani stipulating payment for the purpose of deputing technicians to India for erection, start-up, putting into commission, conducting performance tests and demonstration of performance of the machinery supplied f.o.b. by the non-resident under another contract did not bring about a business connection for the nonresident in India within the meaning of s. 9(1)(i) of the IT. Act ?

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High Court Of Andhra Pradesh CIT vs. Sundwiger Emfg & Co. Sections 5(2), 9(1)(i), 9(1)(vii) Asst. Year 1980-81, 1981-82, 1982-83

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