DTAA with China

Section 9

AAR : Whether in the stated facts and circumstances of the case and the relevant provisions of Income Tax Act read with Double Taxation Avoidance Agreement between Government of India and People’s Republic of China, the amount of service fee received/receivable by the applicant from Usha International Limited in terms of Agreement dated 16.11.2012 for providing services in connection with procurement of goods by Usha International Limited from vendors in China and other related services provided in China is taxable in India and the applicant is liable to pay tax thereon in India?

Authority For Advance Rulings (Income Tax), New Delhi Guangzhou Usha International Ltd., In Re Section : 9 Justice V.S. Sirpurkar,

Sec. 245R

AAR : whether the amounts received/receivable by SEPCOIII Electric Power Construction Corporation, China from Sterlite Energy Private Ltd. (SEPL) upon execution of Offshore Supply Contract No. SEPL/SEPCO-III/JSG-01 dated 10-5-2006 are liable to tax in India under the provisions of Income-tax Act, 1961 and the Agreement for Avoidance of Double Taxation between India and China

Authority For Advance Rulings (Income-Tax), New Delhi SEPCOIII Electric Power Construction Corpn., In Re Assessment Years : 2007-08 To 2009-10

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