Section 9

Section 90, Section 9

AAR : Whether the amounts received/receivable by Joint Stock Company Foreign Economic Association “Technopromexport” (‘applicant’ or ‘JSC Technopromexport’) from National Thermal Power Corporation Ltd. (‘NTPC’) under Contract No. CS9558-102-2-FC-COA-4520 dt. 25th March 2005 (‘offshore supply contract No. 4520’), for offshore supply of all plant and equipment including mandatory spares are liable to tax in India under the provisions of the IT Act, 1961 (Act) and the Agreement for Avoidance of Double Taxation between India and Russia (‘India-Russia tax treaty’)

Authority For Advance Rulings Joint Stock Company Foreign Economic Association “TECHNOPROMEXPORT”, In Re Section 9, 90, DTAA between India &

Sec. 9(1)(Vii), Section 9

AAR : Whether on the facts and circumstances of the case the amounts received by the applicant outside India from the Public Works Department, Government of Tamil Nadu, are in consideration for the sale of designs and drawings, being a capital asset transferred outside India, and whether such receipts would be liable to tax in India under the provisions of the IT Act, 1961 ?

Authority For Advance Rulings GMP International Gmbh, IN RE Section 9(1)(vii), DTAA between India & Germany, Art. 5, DTAA between

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