Tag: Authority For Advance Rulings (Income-Tax)

AAR : Clarification on classification and taxability of Agricultural Seedling Tray under GST.

AUTHORITY FOR ADVANCE RULING TAMILNADU ADVANCE RULING AUTHORITY PAPJM Buildings, II Floor, No.1, Greams Road, Chennai-6 PROCEEDINGS OF THE AUTHORITY FOR ADVANCE RULING U/S.98 OF THE GOODS AND SERVICES TA)( ACT, 2OL7. Members present are: 1.Ms. ManasaGangotri Kata, IRS Joint Commissioner/Member, Office of the Principal Chief Commissioner of GST & Central Excise, Chennai-34. 2. Thiru S. …

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?

Authority Of Advance RulingsÂ HM Publishers Holdings Limited In Re Section : 90, 245Q(1) R.S. Shukla, In-Charge Chairman & Ashutosh Chandra, Member (Revenue) A.A.R. No 1238 of 2012 6th June, 2018 Counsel Appeared: Kanchun Kaushal, FCA Dhanesh Bafna, FCA K. Venkatchalam, FC for the Applicant.: Kavita Pandey, CIT (DR), AAR Rajat Kapoor, JCIT (IT) DR for …

AAR : An advance ruling has been requested on the taxability of fees in respect of the services rendered with regard to use of a global network and infrastructure to process card payment transactions for customers in India

Authority Of Advance Rulings Master Card Asia Pacific PTE. Ltd. In Re Section 245Q(1), 133(6), 143(3) R.S. Shukla, In-Charge Chairman & Ashutosh Chandra, Member (Revenue) A.A.R. No. 1573 of 2014 6th June, 2018 Counsel Appeared: S. Ganesh, Senior Advocate Rohinton Sindhwa, CA Harit Tandon, CA G. Chandrashekhar, CA Gaurav Saxena, CA Paras Sharma, CA for the …

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

Authority Of Advance Rulings Saudi Arabian Oil Company In Re Section 245Q(1), 9(1)(b) R S Shukla, In-Charge Chairman & Ashutosh Chandra, Member (Revenue) AAR No. 25 of 2016 31st May, 2018 Counsel appeared: S. Ganesh, Sr. Advocate Shatanik Chakraborty, Advocate Akhil Sambhar, CA Mr. Vinay Aggarwal, CA for the Applicant.: Kavita Pandey, CIT (DR) Sanjay Pandey, …

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 & Ashutosh Chandra, Member (Revenue) AAR No 1010 of 2010 24th May, 2018 Counsel Appeared: Nageswar Rao, Advocate Purushottam Anand, Adv. Akanksha Gupta, CA for the Applicant.: G.C. Srivastava, Advocate Kavita Pandey, CIT (DR), AAR Sukh Sagar …

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’’)

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 (Revenue) AAR No 1319 of 2012 24th May, 2018 Counsel Appeared: S P Singh, AR RishabhAgarwal, AR KeshavAgarwal, AR AmitPahwa, AR for the Applicant.: KavitaPandey, CIT (DR) VijayendraR, ACIT (DR) for the Department ASHUTOSH CHANDRA, MEMBER …

AAR : What is the applicable GST rate for Coir Pith?

AUTHORITY FOR ADVANCE RULING TAMILNADU ADVANCE RULING AUTHORITY PAPJM Buildings, II Floor, No.I, Greams Road, Chennai-6 PROCEEDINGS OF THE AUTHORITY FOR ADVANCE RULING U/S.98 OF THE GOODS AND SERVICES TA)( ACT, 2O17. GSTIN Number, if any / User id 33AKYPP4I I7D1Z2 M/s.Jeena Exports Registered Address/Address provided while obtaining user id No. 1 1A, Spencer Compound, Dindigul, …

AAR : Entitlement to take credit of tax paid on various goods and services used for maintenance of applicant’s township, guest house, hospital, horticulture in its ordinary course of business.

AUTHORITY FOR ADVANCE RULING TAMILNADU ADVANCE RULING AUTHORITY PAPJM Buildings, II Floor, No.l, Greams Road, Chennai-6 PROCEEDINGS OF THE AUTHORITY FOR ADVANCE RULING U/S.98 OF THE GOODS AND SERVICES TA)( ACT, 2OL7. Members present are: 1.Ms. ManasaGangotri Kata, IRS Joint Commissioner/Member, Office of the Principal Chief Commissioner of GST & Central Excise, Chennai-34. 2. Thiru S. …

AAR-New Delhi : Where applicant purchases a residential house abroad in assessment year 2012-13 out of capital gain on sale of inherited property in India within two years from date of sale, he has to be allowed benefit of deduction under section 54

Authority For Advance Rulings, New Delhi Dipankar Mohan Ghosh, In re Section : 54 Assessment Year : 2012-13 R.S. Shukla, Incharge Chairman And Ashutosh Chandra, Member Revenue A.A.R. No. 1356 of 2012 December Â 22, 2017 RULING Ashutosh Chandra, Member Revenue – The applicant is an individual and a holder of British Passport, settled and residing in …

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”)

AUTHORITY FOR ADVANCE RULINGS (INCOME TAX), NEW DELHI Production Resource Group, In re Section 9 R.S. SHUKLA, INCHARGE-CHAIRMAN AND ASHUTOSH CHANDRA, MEMBER REVENUE A.A.R. NO 1330 OF 2012 NOVEMBER 8, 2017 RULING Ashutosh Chandra, Member – Production Resource Group (the Applicant), is a company registered in Belgium and is engaged in the business of providing technical …