Sec. 9(1)(vi)

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 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 ?

/

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

AAR : Whether pursuant to the cost contribution agreement proposed to be entered by the applicant with ABB Research Ltd., Zurich (“ABB Zurich”), the payments to be made to ABB Zurich, representing the applicant’s share of the costs incurred towards basic research and development (“R&D”) activities, constitutes “income” in the hands of ABB Zurich within the meaning of the term in s. 2(24)

/

Authority For Advance Rulings ABB Ltd., IN RE Section 9(1)(vi), 195, DTAA between India & Switzerland, art. 7, DTAA between

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”) ?

/

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)(vi), Section 90

Madras H.C : Whether, on the facts and in the circumstances of the case and in terms of the Double Taxation Avoidance Agreement (DTAA) with Germany, the Tribunal was right in holding that the payment made to the assessee-foreign company was taxable at the rate of 20 per cent as technical know-how fees and not at 30 per cent as royalty ?

/

High Court Of Madras CIT vs. Barmag AG, West Germany Section 9(1)(vi), 90, 115A, 260A Asst. Year 1992-93 P.D. Dinakaran

Scroll to Top
Malcare WordPress Security