267 ITR

Sec. 10(15)

AAR : Whether, in the facts and circumstances of the case and having regard to the terms of borrowal with the foreign company and also the clauses of the Double Taxation Avoidance Agreement between India and Mauritius, the applicant is required to deduct tax at source under the laws for the year ended 31st March, 2002, on the payment of interest to the foreign company especially when the foreign company has no permanent establishment in India and interest income is exempt from tax?

Authority For Advance Rulings Yu Bo Investment Company (P) Ltd., In Re Sections 10(15)(iv), 193, Double Taxation Avoidance Agreement between

Section 90

AAR : Whether the income receivable by M/s Flakt Woods AB (hereinafter referred to as “Flakt AB”) which is a company incorporated in Sweden and accordingly a tax resident of Sweden, in the form of “royalties” from M/s Flakt (India) Limited (hereinafter referred to as the “applicant”) under the IP Licence and Fee Agreement and Trademark Licence and Fee Agreement, would be subject to tax in its hands in India only on cash or receipt basis, as per the provisions of art. 12 of the Double Taxation Avoidance Agreement entered into between the Government of India and the Government of the Sweden (hereinafter referred to as “India-Sweden tax treaty”?

Authority For Advance Rulings Flakt (India) Ltd., In Re DTAA between India & Sweden, art. 12, DTAA between India &

Income Tax Case Laws

S.C : The present appeal is directed against the judgment and order dt. 30th April, 2001, in Writ Petn. No. 1617 of 1998 passed by the High Court of judicature at Madras whereby the Division Bench of the Madras High Court dismissed the writ petition of the appellant-association and held ss. 66, 67 (o) of the Finance Act, 1994 and r. 2(1)(d)(ix) of the Service-tax Rules, 1994, and other provisions related to Kalyana Mandapams and Mandap-keepers to be intra vires of the Constitution of India.

Supreme Court Of India Tamil Nadu Kalyana Mandapam Association vs. Union Of India & Ors. Sections ART. 366(29A)(f), Sch. VII,

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