Authority For Advance Rulings (Income-Tax) Archives - Page 21 of 22

AAR : The applicant is a resident of USA and was on regular employment with SAP Singapore, another company of the said group. SAP Singapore has deputed her to SAP India as its President for a period of 2 years commencing from 1st April, 1999.

Avijit Das / March 7, 2001

Authority For Advance Rulings Ms. Ruth Connolly, In Re Section 10(5B) Suhas C. Sen, J., Chairman; Dr. Mohini Bhussry & […]

Sec. 10(5B), Section 10

AAR : Whether the applicant satisfies the definition of Yes “technician” for the purpose of s. 10(5B).

Avijit Das / March 7, 2001

Authority For Advance Rulings Dr. U. Muralidharan, In Re Section 10(5B) Suhas C. Sen, J., Chairman; Dr. Mohini Bhussry &

Section 90

AAR : Whether, on the facts and circumstances of the case, XYZ/ABC Equity Fund, (hereinafter referred to as the “Applicant”) will be a resident in Mauritius and hence, entitled to the benefits of the Convention between the Government of the Republic of India and the Government of Mauritius for Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains and for Encouragement of Mutual Trade and Investment, as notified on 6th Dec., 1983 (hereinafter referred to as the “Treaty”)

Avijit Das / March 7, 2001

Authority For Advance Rulings XYZ/ABC, Equity Fund, In Re Sections 90, 139(1), Double Taxation Avoidance Agreement between India and Mauritius,

Sec. 2(22), Sec. 2(22)(A), Sec. 2(23)

AAR : Whether the applicant is chargeable to tax in respect of income earned from business, as computed under art. 7 of the treaty from asst. yr. 1996-97, at the rate applicable to a domestic company, in so far as is beneficial to the applicant

Avijit Das / December 4, 1998

Authority For Advance Rulings ABC, In Re Sections 2(22A), 2(23A), 2(26), 90(2) Suhas C. Sen, J., Chairman; Dr. Subhash C.

Sec. 115JA

AAR : Whether the provisions of s. 115JA of the Act would be applicable in computing the total income of a foreign company like the applicant

Avijit Das / July 20, 1998

Authority For Advance rulings XYZ, IN RE Section 115JA Suhas C. Sen., J; Chairman ; Mohini Bhussry, Member P. No.

Sec. 44BB

AAR : Whether remuneration paid to employees [residents of Australia] of the applicant satisfies sub-cl. (c) of cl. 2 of Art. 15 of the Agreement for Avoidance of Double Taxation (‘DTA’) concluded between India and Australia

Avijit Das / April 30, 1997

Authority For Advance Rulings LLoyd Helicopters International Pty. Ltd., In Re Sections 44BB, 44BBA, 245N(a) S. Ranganathan, J., Chairman; Bhuvanendra

Section 90

AAR : This is an application under s. 245Q(1) of the IT Act, 1961 (‘the Act’). The applicant is TVM Limited, a company incorporated in Mauritius on 23rd May, 1995. It is stated that the effective place of management of the company is in Mauritius and that, therefore, the applicant is a nonresident under s. 6 of the Act.

Avijit Das / March 18, 1997

Authority For Advance Rulings TVM Ltd., In Re Section 90(2) S. Ranganathan, J. Chairman; R.L. Meena & Bhuvanendra Nigam, Members

Sec. 10(5B)

AAR : Whether, on the facts and in the circumstances of the case, exemption under s. 10(5B) of the IT Act, 1961 would be available to the applicant ?

Avijit Das / August 20, 1996

Authority For Advance Rulings Arthur E. Newell, In Re Sections 10(5B), 10(6)(vi) Asst. Year 1995-96 S. Ranganathan, J., Chairman &

Sec. 44D

AAR : The applicant company has been established with the objects of “marketing, sale, hire, procurement and other distribution of products and services within radio and telecommunication and the carrying on other activities compatible with or related to these objects

Avijit Das / June 20, 1996

Authority For Advance Rulings Ericsson Telephone Corporation India Ab, In Re Sections 44D, 115A, 195, 245R(2), Proviso (a), 1995FA SCH.

Sec. 245Q, Sec. 245R, Section 245

AAR : These certificates declare that the applicants are “qualified in terms of the aforesaid convention as resident in Mauritius

Avijit Das / December 22, 1995

Authority For Advance Rulings XYZ, In Re Sections 245Q(1), 245R(2), proviso first, CL (c) S. Ranganathan, J., Chairman; D.B. Lal