DTAA with Singapore

Section 6, Sec. 6(3)

AAR : Whether looking to the nature of activities carried on by the Applicant, which is a Singapore based company and a non-resident as per provisions of section 6(3) of the Income Tax Act, 1961, the Applicant can be held to have earned any income taxable in India from its activities of execution of “Installation Project” referred herein, as per the provisions of Income Tax Act, 1961

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Authority Of Advance Rulings Tiong Woon Project & Contracting (Pte) Limited., In Re Section 6(3) V.S. Sirpurkar, Chairman, A.K. Tewary,

Section 9

AAR : The applicant has no office, equipment, employee or agent in India and no operations are carried out by the applicant in India, whether there exists (i) a permanent establishment (PE) of the applicant in India in connection with the international express business under the “agreement between the Government of Singapore and the Government of the Republic of India for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income. (‘the India-Singapore tax treaty)” or (ii) any other basis to attribute or allocate income taxable in India to the applicant

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Authority For Advance Rulings (Income Tax), New Delhi Aramex International Logistics (P.) Ltd., In Re Section : 9 Justice P.K.

Section 90

AAR : Whether the payments made by the applicant to AXA ARC for various services under the terms of the service agreement is in the nature of ‘fees for technical services’ within the meaning of the term in art. 12 of the ‘Convention between the Government of Republic of India and the Government of Republic of Singapore for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income’ (“the India-Singapore tax treaty)

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Authority For Advance Rulings Bharati AXA General Insurance Co. Ltd., IN RE DTAA between India & Singapore, arts. 12.3 &

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