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DTAA with France

Section 9, Section 195

AAR : In absence of ‘make available’ clause in India-France DTAA payments made by applicant, an Indian company, to a French company for management services rendered comes under definition of fees for technical services both under Act and Treaty and is liable to tax in India

Avijit Das / May 2, 2014

Authority For Advance Rulings (Income Tax) New Delhi Steria (India) Ltd., In Re Section : 9, 195 Justice Dr. Arijit […]

Andhra Pradesh H.C : Where, a French company, incorporated to serve as an investment vehicle of foreign direct investment in India, transferred its interest in Indian concern to another French company, in view of provisions of article 14(5) of Indo-French DTAA, capital gain arising on said transfer would be taxable in France

Avijit Das / February 15, 2013

High Court Of Andhra Pradesh Sanofi Pasteur Holding Sa Vs. Department Of Revenue, Ministry Of Finance Section : 9 Goda

Sec. 2(31), Section 142

Kerala H.C : Shares of ShanH were held by two French Companies namely MD and GIMA – A share purchase agreement (SPA) was entered into between MD/GIMA and Sanofi, a French company, in terms of which shares of ShanH were transferred to Sanofi

Avijit Das / February 13, 2013

High Court Of Kerala Mangalam Service Co-Operative Bank Ltd. vs. ITO, Tirpur Section : 2(31), 142 K.M. Joseph And K.

Section 5, Section 9

AAR : Whether the amounts received/receivable by ATSA under the BMRCL contract, for offshore services are chargeable to tax in India under the provisions of the Act and India-France tax treaty

Avijit Das / June 7, 2012

Authority For Advance Rulings (Income Tax), New Delhi Alstom Transport Sa, In Re Section : 9, 5 Justice P.K. Balasubramanyan,

AAR : Whether the services as per proposed agreement would fall under the definition of Section 9(1)(vi) or Section 9(1)(vii) or both

Avijit Das / February 7, 2012

Authority For Advance Rulings (Income Tax), New Delhi Areva T&D India Ltd., In Re Section : 9(1)(Vii) Justice P.K. Balasubramanyan,

AAR : Whether since essence of transaction in question takes within its sweep various rights including a change in controlling interest of an Indian company (Shantha) having assets, business and income in India, it has to be ruled that transaction of sale of shares by applicant in ‘ShanH’ to ‘Sanofi’ is taxable in India in terms of paragraph 5 of Article 14 of India – France DTAA

Avijit Das / November 28, 2011

Authority For Advance Rulings (Income-Tax), New Delhi Groupe Industrial Marcel Dassault, In Re Section : 9 Justice P.K. Balasubramanyan, Chairman

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