Authority For Advance Rulings (Income-Tax)

Income Tax Case Laws, Sec. 245Q, Section 90

AAR : Whether on the facts and circumstances of the case the non-compete fees received by the Applicant from ADI BPO Services Private Ltd., an Indian Company, as a part of the consideration for transfer of the shares held in MPS Ltd. an Indian Company, shall be chargeable under the head “Profits and gains of business or profession” as provided under Section 28(va) of the Income-tax Act read with Article 7 of the Double Tax Avoidance Agreement (‘DTAA’) between India and United Kingdom, in absence of any Permanent Establishment of the Applicant in India?

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Authority Of Advance Rulings  HM Publishers Holdings Limited In Re Section : 90, 245Q(1) R.S. Shukla, In-Charge Chairman & Ashutosh

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

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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

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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 &

Sec. 245Q, Sec. 2(24), Sec. 2(24)(iii), Sec. 28(iii)

AAR : The representative/liaison office (LO) proposed to be established by IZA in India would be liable to income-tax in India under the provisions of the Act or the provisions of Double Taxation Avoidance agreement between India and Belgium (‘India -Belgium DTAA’’)

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Authority Of Advance Rulings International Zinc Association In Re Section 245Q(1), 28(iii), 2(24)(iii) R.S. Shukla, In-Chargechairman & Ashutosh Chandra, Member

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”)

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

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