Sec. 9(1)(i) Archives - taxcaselaw.com

Sec. 5(2), Sec. 201(1), Sec. 201(1A), Sec. 9(1)(i), Section 195, Section 201

Bombay H.C : HEL is an Indian company in which shares were acquired by the Hutchison Group of com arrangement of holding and subsidiary companies

Avijit Das / September 8, 2010

High Court Of Bombay Vodafone International Holdings B.V. vs. Union Of India & Anr. Section 5(2), 9(1)(i), 195, 201(1), 201(1A) […]

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 ?

Avijit Das / July 23, 2010

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.

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

AAR : Whether AramCo Overseas Company BV (‘applicant’) will be taxable in India, in respect of support services rendered by its Indian office for purchases made by the applicant and its group company, in light of the provisions of the IT Act, 1961

Avijit Das / March 12, 2010

Authority For Advance Rulings Aramco Overseas Company Bv, In Re Section 5(2), 9(1)(i), Expln. 1(b) P.V. Reddi, J., Chairman; J.

Section 9, Sec. 9(1)(i), Section 195, Section 90

AAR : Whether the amount receivable by Laird USA as per the assignment agreement is taxable in India having regard to the provisions of the Act and the Double Taxation Avoidance Agreement between India and USA (‘the DTAA’

Avijit Das / February 18, 2010

Authority For Advance Rulings Laird Technologies India (P) Ltd., In Re Section 9(1)(i), 90, 195, DTAA between India & USA,

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

Karnataka H.C : Whether the Tribunal was justified in holding that the income received by IIT, Chicago from the assessee cannot be treated as an income liable to tax as per the provisions of the Indian IT Act ?

Avijit Das / August 6, 2008

High Court Of Karnataka CIT (International Taxation) & Anr. vs. Illinois Institute Of Technology (India) (P) Ltd. Section 9(1)(i), 195,

Sec. 9(1)(i), Section 160, Section 163, Section 45

AAR : Whether Mr. Jeff Slosar, US resident, transferor of 17,500 equity shares of TASL (P) Ltd., an Indian company is liable for capital gains tax on transfer of such shares to Triniti Corporation, a US company.

Avijit Das / November 16, 2007

Authority For Advance Rulings Triniti Corporation, IN RE Section 9(1)(i), 45, 160, 163, DTAA between India and USA, art. 13

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

AAR : Whether the payment is for services or for the use of the brand ?

Avijit Das / November 27, 2006

Authority For Advance Rulings International Hotel Licensing Company S.A.R.L., In Re Sections 9(1)(i), 9(1)(vii) Syed Shah Mohammed Quadri, J., Chairman

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

AAR : Whether the receipt arising to the applicant, from the proposed assignment of the turbocharger development and supply agreements in accordance with the assignment deeds be taxable in India having regard to the provisions of the IT Act, 1961 (“the Act”) and the Double Taxation Avoidance Agreement between India and Switzerland (“the DTAA”) ?

Avijit Das / August 21, 2006

Authority For Advance Rulings ABC Ltd., In Re Sections 9(1)(i), 9(1)(vi), 195 Syed Shah Mohammed Quadri, J., Chairman & A.S.

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

AAR : Whether looking to the nature of activities to be carried on by the liaison office (as proposed to be set up in India by UAE based Gutal Trading Est.) the applicant can be held to have earned any income ?

Avijit Das / September 28, 2005

Authority For Advance Rulings Gutal Trading Est., In Re Section 9(1)(i), DTAA between India & UAE, Art. 4(1) Syed Shah

Sec. 2(47), Sec. 9(1)(i)

AAR : Whether, in respect of the transaction, being the reorganization described in Annex. 2 of this application, the applicant is chargeable to tax in India under the provisions of the IT Act, 1961, or the Agreement for Avoidance of Double Taxation between India and the United Kingdom

Avijit Das / July 29, 2005

Authority For Advance Rulings Citicorp Trustee Company Ltd., In Re Section 2(47), 9(1)(i) Syed Shah Mohammed Quadri, J., Chairman &