Section 9

Sec. 245Q, Section 9

AAR : Based on the nature of business support/ marketing support activities proposed to be undertaken by the Indian affiliate entity viz. Aramco Asia India Private Limited (hereinafter “Aramco India”), as listed in the Statement of relevant facts (Annexure III), would Aramco India create a Permanent Establishment (“PE”) for the Applicant in India under Article 5 of Double Taxation Avoidance Agreement between India and Kingdom of Saudi Arabia (hereinafter “India-Saudi Arabia DTAA”), where such activities of Aramco India are duly compensated on an Arm’s Length basis in accordance with the Indian transfer pricing laws and regulations

Authority Of Advance Rulings Saudi Arabian Oil Company In Re Section 245Q(1), 9(1)(b) R S Shukla, In-Charge Chairman & Ashutosh

Sec. 245Q, Sec. 9(1)(vi)

AAR : Payments received by the Applicant from the Indian hotel owner for provision of global reservation services (‘GRS’) would be chargeable to tax in India as ‘Fees for Technical Services’or ‘Royalty’under the provisions of section 9(1)(vi) / 9(1)(vii) of the Income tax Act, 1961 (“the Act”) read with provisions of Article 12 of the Double Taxation Avoidance Agreement between India and Luxembourg

Authority Of Advance Rulings FRS Hotel Group (Lux) S.A.R.L. In Re Section 245Q(1), 9(1)(vi), 10.2 R.S. Shukla, In-Charge Chairman &

Section 9

AAR-New Delhi : Where applicant an Indian company entered into two agreements with a French company for offshore equipment supply and for supervision of installation services, no income from offshore supply of equipment would be taxable in India as business connection through supervision on Indian premises later had no connection with this supply

Authority For Advance Rulings, New Delhi Michelin Tamil Nadu Tyres (P.) Ltd., In re Section 9 R.S. Shukla, (In-Charge), Chairman

Section 9

AAR – NewDelhi : The payments received/to be received by the Applicant for rendering, lighting and searchlight services to the Organizing Committee, Commonwealth Games 2010, Delhi (hereinafter referred to as “ÖCCG”) under the Agreement dated 9th July, 2010 would be taxable in India under the provisions of the Income tax Act, 1961 (“the Act”)

AUTHORITY FOR ADVANCE RULINGS (INCOME TAX), NEW DELHI Production Resource Group, In re Section 9 R.S. SHUKLA, INCHARGE-CHAIRMAN AND ASHUTOSH

Section 9, Section 147, Section 148

Delhi H.C : Where assessment was sought to be reopened in case of assessee, a Mauritius based TV program distributor, on ground that subscription fees received by it from Indian AE was taxable under section 9(1)(i) while, in fact, assessee had not conducted any business with ‘AE’ during relevant year, reason for reopening of assessment was invalid

High Court Of Delhi ESS Distribution (Mauritius) S.N.C.E.T Compagnie vs. ACIT, Circle-1(2)(2), International Taxation, New Delhi Section 9, 147, 148 Muralidhar And

Scroll to Top
Malcare WordPress Security